conflict minerals and makes no purchases in the Democratic Republic of the Congo (the “DRC”) or any country adjoining the DRC, including the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (all defined in the Rule as the “Covered Countries”).
Company Description and Products Covered by this Report
TiVo is a global leader in entertainment technology and audience insights. From the interactive program guide to the DVR, TiVo delivers innovative products and licensable technologies that revolutionize how people find content across a changing media landscape. As part of these technologies and services, TiVo is a global provider of software for digital video recorders and otherset-top box products for multichannel video programming distributors and consumers.
Although we design, engineer, and distribute the digital video recorders and otherset-top box hardware products, TiVo does not manufacture any of those hardware products itself. TiVo outsources to third parties the manufacturing of its hardware products. In determining which products werein-scope for purposes of this Report, TiVo took into account the amount of influence TiVo has over the manufacture and design of the products. TiVo determined that there were one or more conflict minerals that were necessary to the functionality or production of the TiVo BOLT models of digital video recorders (the “Covered Products”). This Report relates to Covered Products the manufacture of which was completed during the Reporting Period.
ReasonableCountry-of-Origin Inquiry
For the Reporting Period, TiVo conducted a reasonablecountry-of-origin inquiry to determine whether any of the conflict minerals that were necessary to the functionality or production of the Covered Products originated in a Covered Country or were from recycled or scrap sources.
To conduct its reasonablecountry-of-origin inquiry, the TiVo requested that its direct supplier of the Covered Product, the “Contract Manufacturer,” providecountry-of-origin information for the conflict minerals included in the Covered Products. TiVo believes that the Contract Manufacturer evaluated data from its suppliers, including Conflict Minerals Reporting Templates of the Responsible Minerals Initiative (“RMI”). TiVo reviewed the response from its Contract Manufacturer, focusing on changes that had occurred in the supply chain from 2018 to 2019.
Based on the results of thatcountry-of-origin inquiry, we had reason to believe that some of the conflict minerals contained in the Covered Products may have originated in one or more of the Covered Countries. Accordingly, we conducted due diligence on the source and chain of custody of those conflict minerals.
Due Diligence Process
TiVo has a complex supply chain. The supply chain involves many parties between the Contract Manufacturer of our Covered Products and the original sources of conflict minerals. TiVo does not directly purchase conflict minerals from mines, smelters, or refiners. We must therefore rely on our Contract Manufacturer and its suppliers to provide information regarding the origin of conflict minerals that may be included in our products and to identify the smelters and refiners of conflict minerals in our supply chain.
Our due diligence measures were originally designed to conform, in all material respects, with the “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition)” and the related supplements, published by the Organisation for EconomicCo-operation and Development (the “OECD Guidance”), consistent with our position as a downstream company.
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