Exhibit 1.01
CONFLICT MINERALS REPORT
INTEL CORPORATION
INACCORDWITH RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACTOF 1934
This Conflict Minerals Report (Report) of Intel Corporation (Intel or we) for the year ended December 31, 2018 is presented to comply with Rule13p-1 under the Securities Exchange Act of 1934, as amended (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting requirements related to “conflict minerals,” defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are limited to tantalum, tin, and tungsten.
The Rule imposes certain reporting obligations on SEC registrants whose products contain conflict minerals that are necessary to the functionality or production of their products (referred to as “necessary conflict minerals”). For products that contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the necessary conflict minerals originated in the Democratic Republic of the Congo (DRC) or an adjoining country (collectively, the “Covered Countries”). If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals originated or may have originated in a Covered Country and may not be solely from recycled or scrap sources, the registrant must conduct due diligence to determine if the necessary conflict minerals directly or indirectly financed or benefited armed groups (as defined by the SEC in Form SD) in the Covered Countries.
Overview of Intel’s Conflict Minerals Program
Many of our hardware products contain tantalum, tin, tungsten and/or gold necessary to the functionality or production of those products. Conflict minerals are obtained from sources worldwide, and our desire is not to eliminate those originating in the Covered Countries but rather to obtain conflict minerals from sources that do not directly or indirectly finance or benefit armed groups in the Covered Countries. We believe that it is important for us and other companies to support responsiblein-region mineral sourcing from the Covered Countries in order to not negatively affect the economies of such countries.
We have worked extensively for over eleven years on the issue of conflict minerals, as part of our work on responsible mineral sourcing, which we define as sourcing done in an ethical and sustainable manner that safeguards the human rights of those involved in our global supply chain. We recognize that broad collaborative efforts among governments,non-governmental organizations and industry are needed to identify and mitigate the risk of contributing to serious human rights abuses and conflict related to mineral extraction in the Covered Countries. Intel is a member of the Responsible Minerals Initiative (RMI), unique member code INTC, and the European Partnership for Responsible Minerals (EPRM), where we collaborate with companies in the electronics and other industries (e.g. jewelry, automotive, medical instrumentation, and others) and other stakeholders, such as public authorities and civil society groups, to address responsible mineral sourcing issues. Additionally, we are members of, and provide support to, the International Tin Association’s International Tin Supply Chain Initiative (iTSCi) and the Public-Private Alliance for Responsible Minerals Trade (PPA), which promote responsibly sourced minerals from the Covered Countries. We are also part of the CRAFT Code Committee, which assisted in the development of theCode of Risk-mitigation for Artisanal and Small-Scale Mining engaging in Formal Trade (CRAFT).
Supply Chain Description
Most of our hardware products, primarily microprocessors, chipsets and their packages, are manufactured in our own network of fabrication facilities (fabs). Although many of our hardware products contain conflict minerals, we do not purchase ore or unrefined conflict minerals from mines. We are many steps removed in the supply chain from the mining of conflict minerals and are therefore considered a “downstream” purchaser. We purchase materials used in our products from a large network of suppliers; some of those materials contribute necessary conflict minerals to our products. The origin of conflict minerals cannot be determined with any certainty once the ores are smelted, refined and converted to ingots, bullion or other derivatives. The smelters and refiners (referred to as “facilities”) are consolidating points for ore and are in the best position in the total supply chain to know the origin of the ores. We rely on our suppliers to assist with
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our reasonable country of origin inquiry and due diligence efforts, including the identification of smelters and refiners, for the conflict minerals contained in the materials which they supply to us. We are more knowledgeable about the source and chain of custody of the necessary conflict minerals contained in products we fully manufacture in our fabs, as compared to products which we manufacture but which also include ready-made component parts we purchase from third parties, or products that are manufactured for us by other companies.
Design of Conflict Minerals Program
The design of Intel’s conflict minerals program is in conformity with theOrganisation for EconomicCo-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs), Third Edition, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, “OECD Guidance”), specifically as it relates to our position in the minerals supply chain as a “downstream” purchaser. Summarized below are the design components of our conflict minerals program as they relate to the five-step framework from the OECD Guidance:
| 1. | Maintain strong company management systems: |
| • | Conflict Minerals Sourcing Policy: Maintain a supply chain policy for conflict minerals originating from the Covered Countries that includes our commitment to exercise due diligence consistent with the OECD Guidance. That policy is available atwww.intel.com/conflictfree and has been updated as of March 2019 to include our expanded commitment to collaborate with customers, suppliers, and industry associations on long-term solutions to enable responsible mineral sourcing. |
| • | Internal Responsible Minerals team: Operate an internal Responsible Minerals team led by our Global Supply Management organization to implement our Conflict Minerals Sourcing Policy. We review such efforts with our Chief Executive Officer (CEO) and senior management of our Technology and Manufacturing Group (TMG). |
| • | Supply chain control system: Employ a supply chain system of controls and transparency through the use of due diligence tools such as the Conflict Minerals Reporting Template (CMRT), a supply chain survey designed by the RMI to identify the smelters and refiners that process the necessary conflict minerals contained in our products and the country of origin of those conflict minerals. We employ a database to assess due diligence information and maintain records relating to our responsible minerals program for at least five years, in accordance with our record retention guidelines. |
| • | Supplier engagement: Feature requirements related to conflict minerals in our standard template for supplier contracts and specifications so that current and future suppliers are obligated to comply with our policies on conflict minerals, including participation in a supply chain survey and related due diligence activities. We communicate our Conflict Minerals Sourcing Policy and contractual requirements to relevant suppliers annually. |
| • | Company grievance mechanism: Enable employees, suppliers and other stakeholders to report any concerns relating to our conflict minerals program through our online corporate responsibility reporting and grievance mechanism found on our company website athttps://www.intel.com/content/www/us/en/corporate-responsibility/corporate-responsibility.html. |
| 2. | Identify and assess risks in our supply chain: |
| • | Identify smelters/refiners in our supply chain: Identify direct suppliers that supply products to Intel that may contribute necessary conflict minerals to our products. Conduct an annual supply chain survey requesting those direct suppliers to provide a conflict minerals declaration, using the CMRT, designed to identify the conflict minerals contained in the products they supply to Intel, the smelters and refiners that processed those conflict minerals, and the country of origin of those conflict minerals. We evaluate the completeness and accuracy of the suppliers’ survey responses and contact suppliers whose survey response we identified as having contained incomplete or potentially inaccurate information in order to seek additional clarifying information. |
| • | Identify the scope of the risk assessment: Our risk assessment is designed to identify risks in our supply chain. This includes direct suppliers not meeting our contractual requirements related to conflict minerals as well as smelters and refiners that are not conformant to a responsible mineral sourcing validation program or that we have reason to believe may source conflict minerals from the Covered Countries. We document mineral country of origin information for the smelters and refiners |
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identified by the supply chain survey, as provided from sources including the supply chain survey, responsible mineral sourcing validation programs, direct contact with smelters and refiners, and from publicly available sources such as smelter and refiner websites. |
| • | Assess due diligence practices of smelters and refiners: Compare smelters and refiners identified by the supply chain survey against the list of facilities that are conformant to a responsible mineral sourcing validation program such as the RMI’s Responsible Minerals Assurance Program (RMAP), or other RMI cross-recognized, independent third party audit programs. |
| • | Carry out spot checks of smelters and refiners: Conduct spot checks of smelter and refiner due diligence practices by attempting to visit those facilities that are not conformant to a responsible mineral sourcing validation program and which allowed our visit. Our smelter and refiner visits are designed to assess their due diligence practices, request country of origin and chain of custody information for the conflict minerals processed by the facilities and encourage and assist their participation in such a program. |
| 3. | Execute a strategy to respond to identified risks: |
| • | Report findings to senior management: Provide progress reports to our CEO and TMG senior management summarizing information gathered during our annual supply chain survey, results from the risk assessment process and status of our risk mitigation efforts. |
| • | Devise and adopt a risk management plan: Maintain a risk management plan that includes due diligence reviews of suppliers, smelters and refiners that may be sourcing or processing conflict minerals from the Covered Countries which may not be from recycled or scrap sources. Our due diligence measures are significantly based on responsible mineral sourcing validation programs that evaluate the procurement practices of the smelters and refiners that process and provide those conflict minerals to our supply chain. |
| • | Implement a risk management plan: Perform risk mitigation efforts to bring suppliers into conformity with our Conflict Minerals Sourcing Policy or contractual requirements, which efforts may include working with direct suppliers to consider an alternative source for the necessary conflict minerals. Attempt to contact smelter and refiner facilities that are not conformant to a responsible mineral sourcing validation program to assess their due diligence practices, request country of origin and chain of custody information for the conflict minerals processed by the facilities and encourage and assist their participation in such a program. |
| • | Ongoing risk monitoring: Monitor and track suppliers, smelters, and refiners identified as not meeting the requirements set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements. |
| 4. | Support the development and implementation of independent third party audits of smelters’ and refiners’ sourcing: |
| • | Support development and implementation of due diligence practices and tools such as the CMRT through our leadership in the RMI’s Steering Committee and participation within RMIsub-teams. |
| • | Support development and implementation of the RMAP by defining the terms of the RMAP audit protocol in conjunction with RMI member companies and other industry groups. |
| • | Support responsible mineral sourcing validation programs that carry out independent third party audits of smelter and refiner facilities, such as the RMAP, through our membership in and financial support of the RMI (unique member code INTC). |
| 5. | Report on supply chain due diligence: |
| • | Publicly communicate our Conflict Minerals Sourcing Policy on our company website atwww.intel.com/conflictfree. |
| • | Report annually on our supply chain due diligence activities in our white paper titled “Intel’s Efforts to Achieve a Responsibly Sourced Mineral Supply Chain” and Corporate Responsibility Report available on our company website atwww.intel.com/conflictfree. |
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| • | Obtain an independent private sector audit of applicable sections of this Report and file a Form SD with the SEC. This information is publicly available on our company website atwww.intel.com/conflictfree. |
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.
Description of Reasonable Country of Origin Inquiry Efforts
For 2018, our reasonable country of origin inquiry (RCOI) efforts included conducting a supply chain survey of our direct suppliers (referred to as “surveyed suppliers”) using the CMRT. The supply chain surveys requested our suppliers to identify the smelters and refiners and countries of origin of the conflict minerals in products they supply to us. We compared the smelters and refiners identified in the surveys against the lists of facilities which are conformant to a responsible mineral sourcing validation program, such as the RMAP or RMI cross-recognized programs. We also proactively attempted to contact smelter and refiner facilities identified by our surveyed suppliers where we did not have mineral country of origin information and requested each facility contacted to identify the types of raw materials processed by the facility and the mineral country of origin for ore processed by that facility. We documented country of origin information for the smelter and refiner facilities identified by surveyed suppliers as provided from sources including the supply chain survey, responsible mineral sourcing validation programs, direct contact with smelters and refiners, and from publicly available sources such as smelter and refiner websites, if we determined such publicly available sources to be reliable.
Results of Reasonable Country of Origin Inquiry Efforts
For 2018, Intel conducted a supply chain survey of 277 suppliers that we identified may contribute necessary conflict minerals to our products.
The results of our RCOI as of March 1, 2019 are as follows:
| • | 98% of surveyed suppliers provided a CMRT in response to our supply chain survey request. |
| • | The surveyed suppliers identified 257 operational smelter and refiner facilities which may process the necessary conflict minerals contained in the products provided to us. |
| • | We know or have reason to believe that a portion of the conflict minerals processed by 42 of these 257 smelters and refiners may have originated in the Covered Countries and may not be solely from recycled or scrap sources. |
This data includes suppliers to Mobileye, a company Intel acquired in 2017. Mobileye conflict mineral due diligence efforts are completely incorporated into our responsible minerals program. Of the 277 surveyed suppliers, 53 were suppliers to Mobileye that were not otherwise part of the Intel supply chain (“Mobileye-unique” suppliers). As of March 1, 2019, 47 of the 53 Mobileye-unique suppliers, approximately 89%, had provided a CMRT in response to our supply chain survey request (compared with 68% in the previous year’s Report). The information provided by those suppliers is included in the results of our RCOI and the Results of our Due Diligence Measures below. Our response rate for Mobileye-unique suppliers has improved since last year, but is not meeting the overall goal that Intel expects from its supply chain (excluding Mobileye-unique suppliers, our supplier response rate was 100%). Intel’s supplier due diligence with these remaining suppliers is ongoing and we are continuing work on our escalation paths to increase the response rate.
Conclusion Based on Reasonable Country of Origin Inquiry
We have concluded in good faith that during 2018:
| a) | Intel manufactured and contracted with others to manufacture products as to which conflict minerals are necessary to the functionality or production of our products. |
| b) | Based on our RCOI, we know or have reason to believe that a portion of the necessary conflict minerals contained in our products originated or may have originated in the Covered Countries and know or have reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources. |
As a result of the above conclusion and pursuant to the Rule, we undertook due diligence measures on the source and chain of custody of the necessary conflict minerals in our products which we had reason to believe may have originated from the Covered Countries and which may not have come from recycled or scrap sources. There is significant overlap between our RCOI efforts and our due diligence measures performed.
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Description of Due Diligence Measures Performed
Below is a description of the measures performed for this reporting period, as of March 1, 2019, to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products:
| • | Conducted a supply chain survey of suppliers which we identified may be supplying Intel with products that contain necessary conflict minerals using the CMRT, requesting country of origin information regarding the necessary conflict minerals and identification of smelters and refiners that process such minerals. |
| • | Contacted surveyed suppliers on responses to supply chain surveys that we identified as having contained incomplete or potentially inaccurate information to seek additional clarifying information. |
| • | Received a CMRT from 98% of our surveyed suppliers in response to our supply chain survey request. |
| • | Compared smelters and refiners identified by surveyed suppliers against the list of facilities that are conformant to a responsible mineral sourcing validation program. |
| • | Monitored and tracked surveyed suppliers, and smelters and refiners identified by surveyed suppliers, which we identified as not meeting our conflict minerals policy or contractual requirements, to determine their progress in meeting those requirements. |
| • | Performed risk mitigation efforts with surveyed suppliers we identified as not in conformity with our conflict minerals policy or contractual requirements by working with them to bring them into compliance. |
| • | In 2018, visited 2 smelters and refiners that were not conformant with a responsible mineral sourcing validation program to collect country of origin information and encourage and assist their participation in such a program. |
| • | Provided 12 progress reports to TMG senior management and 2 progress reports to our CEO that summarized the status of our conflict minerals program. |
| • | Obtained an independent private sector audit of applicable sections of this Report, which is set forth as Exhibit A to this Report. |
Results of our Due Diligence Measures
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of products which contain conflict minerals, 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 responsible mineral sourcing validation programs. Such sources of information, as well as our smelters and refiner facility visits and publicly available sources, may yield inaccurate or incomplete information and may be subject to fraud.
Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers and the entire supply chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners. We ask that the data cover the entire reporting year, and we seek to use contract provisions requiring the suppliers to promptly update us in the event that the sourcing data changes.
Surveyed Supplier Due Diligence Results
Intel evaluated the accuracy and completeness of the responses to our supply chain surveys by our surveyed suppliers. We identified 34 surveyed suppliers whose initial survey response contained incomplete or potentially inaccurate information. We used various methods to identify the incomplete or inaccurate information in the surveyed supplier’s response, including verification checks conducted by third party software or by members of our internal Responsible
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Minerals team. When an incomplete or inaccurate response was identified, we contacted the applicable surveyed supplier, identified the incomplete or inaccurate information and requested that the surveyed supplier correct the incomplete or potentially inaccurate information and provide an updated response. 33 of these 34 surveyed suppliers provided an updated CMRT which we determined, using the same evaluation criteria, to be complete and accurate. We continue to work with the remaining supplier on capacity building to ensure accuracy of future declarations.
Upon receiving a survey response identified to be complete and accurate based on our evaluation criteria, we further evaluated each response for conformity with our conflict minerals policy or contractual requirements. These requirements include that our surveyed suppliers must maintain a publicly available conflict minerals sourcing policy, provide a CMRT upon our request, and use smelters and refiners which are either conformant to a responsible mineral sourcing validation program, have begun participating in such a program, or are included among the facilities that we have reasonably concluded, through our own due diligence activities, do not process conflict minerals which originated from the Covered Countries. We identified surveyed suppliers which were not fully compliant with all applicable requirements and monitored and tracked these suppliers’ progress in meeting the applicable requirements. We performed risk mitigation efforts by contacting each supplier, identifying actions items which we requested the supplier complete, and asking the supplier to provide an updated CMRT. Our risk mitigation efforts are specifically related to meeting our conflict minerals policy or contractual requirements, with the goal of bringing each surveyed supplier into compliance with such requirements.
As a result of these supplier due diligence activities, Intel determined that approximately 98% of the surveyed suppliers that had provided a CMRT as of March 1, 2019 (267 out of 271) are in compliance with our conflict minerals policy or contractual requirements. Of the four suppliers not meeting our requirements, two are no longer in our supply chain, and we are continuing to work with the other two suppliers to drive compliance.
Smelter and Refiner Due Diligence Results
As a result of the supply chain survey, our surveyed suppliers identified an aggregate of 257 operational smelter and refiner facilities which may process the necessary conflict minerals contained in the products these surveyed suppliers provided to Intel.
Intel conducted due diligence on these smelters and refiners. Our due diligence activities are dominated by a continual process to determine and monitor whether the identified smelters and refiners are operational and therefore may contribute necessary conflict minerals to our final products, and whether they are conformant to a responsible mineral sourcing validation program or have begun participating in such a program. We also sought reliable information on the source and chain of custody of the conflict minerals processed by such facilities, including from publicly available sources, with the goal to determine if any of these facilities processed conflict minerals that may have originated from the Covered Countries and may not be solely from recycled or scrap sources.
If a smelter or refiner in our supply chain was not yet conformant to a responsible mineral sourcing validation program or had not yet begun participating in such a program, Intel and other RMI member companies proactively attempted to contact such facilities to request country of origin information for the conflict minerals the facilities processed, as well as to encourage and assist their participation in a responsible mineral sourcing validation program and, in some cases, visited such facilitieson-site. We monitored and tracked smelters and refiners which we identified as not being conformant to a responsible mineral sourcing validation program or not having begun participating in such a program.
During this reporting year, we identified 26 smelter and refiner facilities that were not conformant to a responsible mineral sourcing validation program. These facilities were the focus of our smelter and refiner due diligence activities for this reporting period and, as a result of our activities, we reasonably concluded that as of March 1, 2019:
| • | 12 of these 26 smelter and refiner facilities had later become conformant to a responsible mineral sourcing program. |
| • | 4 of these 26 smelter and refiner facilities have begun participating in a responsible mineral sourcing validation program but are not yet conformant. Intel has performed due diligence on these 4 smelters and has reasonably concluded that they do not process conflict minerals originating from the Covered Countries. |
| • | The remaining 10 of these 26 smelter and refiner facilities do not process conflict minerals which originated from the Covered Countries (referred to below as “Intel Validated”). |
As result of our due diligence activities summarized above, we determined the following as of March 1, 2019:
| • | All 257 smelters and refiners identified by our surveyed suppliers were either conformant to a responsible mineral sourcing validation program, have begun participating in such a program, or are facilities that, based on our own due diligence activities, we have reasonably concluded do not process conflict minerals which originated from the Covered Countries. |
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| • | All 42 smelters and refiners which we know or have reason to believe may source conflict minerals from the Covered Countries which may not be solely from recycled or scrap sources are conformant to a responsible mineral sourcing validation program. |
| • | We have no reason to believe that any of the 257 smelter and refiner facilities directly or indirectly finance or benefit armed groups in the Covered Countries. |
Below is a summary of the mineral country of origin information collected as of March 1, 2019 as a result of our due diligence activities:
| Argentina | Finland | Mauritania | Slovakia | |||
| Armenia | Georgia | Mauritius | Solomon Islands | |||
| Australia | Ghana | Mexico | South Africa | |||
| Austria | Guatemala | Mongolia | Spain | |||
| Azerbaijan | Guinea | Morocco | Suriname | |||
| Benin | Guyana | Mozambique | Swaziland | |||
| Bolivia | Honduras | Myanmar | Sweden | |||
| Botswana | India | Namibia | Taiwan | |||
| Brazil | Indonesia | Nicaragua | Tanzania | |||
| Burkina Faso | Iran* | Niger | Thailand | |||
| Burundi | Ivory Coast | Nigeria | Togo | |||
| Canada | Japan | Papua New Guinea | Turkey | |||
| Chile | Kazakhstan | Peru | Uganda | |||
| China | Kenya | Philippines | United Kingdom | |||
| Colombia | Republic of Korea | Poland | United States of America | |||
| Congo, Democratic Republic of the | Kyrgyzstan | Portugal | Uruguay | |||
| Cyprus | Laos People’s Democratic Republic | Puerto Rico | Uzbekistan | |||
| Dominican Republic | Lebanon | Russian Federation | Venezuela | |||
| Ecuador | Liberia | Rwanda | Vietnam | |||
| Egypt | Madagascar | Saudi Arabia | Zambia | |||
| Eritrea | Malaysia | Senegal | Zimbabwe | |||
| Ethiopia | Mali | Sierra Leone |
| * | Minerals from this country were substantially transformed before being incorporated into finished products. Such a substantial transformation of the minerals happened outside of the United States in a third country by a person other than a United States person. |
Summary of Smelter and Refiner Status
The charts below summarize, by conflict mineral, the numbers of operational smelter and refiner facilities, identified by our surveyed suppliers, that as of March 1, 2019:
| (i) | are conformant to a responsible mineral sourcing validation program (referred to as “Conformant”), |
| (ii) | Intel has reasonably concluded, based on our due diligence activities, do not process conflict minerals which originated from the Covered Countries (referred to as “Intel Validated”), or |
| (iii) | have begun participating in a responsible mineral sourcing validation program (referred to as “Active”; as noted above, we have reasonably concluded, based on our due diligence, that none of these facilities process conflict minerals originating from the Covered Countries). |
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Status of Identified Smelters and Refiners
The table below lists the facilities which, to the extent known, processed the necessary conflict minerals in our products based on responses received from our surveyed suppliers as of March 1, 2019. Intel conducts no direct transactions and has no contractual relationship with these smelter and refiner facilities nor their sources of ore.
Metal | Smelter or Refinery Facility Name† | Country† | ||
| Gold | Advanced Chemical Company* | United States of America | ||
| Gold | Aida Chemical Industries Co., Ltd.* | Japan | ||
| Gold | Al Etihad Gold Refinery DMCC* | United Arab Emirates | ||
| Gold | AllgemeineGold-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 | Asahi Refining Canada Ltd.* | Canada | ||
| Gold | Asahi Refining USA Inc.* | United States of America | ||
| 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 |
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Metal | Smelter or Refinery Facility Name† | Country† | ||
| 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 + Metaux S.A.* | Switzerland | ||
| Gold | Chimet S.p.A.* | Italy | ||
| Gold | Chugai Mining** | Japan | ||
| Gold | Daejin Indus Co., Ltd.* | Korea, Republic of | ||
| Gold | DayeNon-Ferrous Metals Mining Ltd.* | China | ||
| Gold | DODUCO Contacts and Refining GmbH* | Germany | ||
| Gold | Dowa* | Japan | ||
| Gold | DSC (Do Sung Corporation)* | Korea, Republic of | ||
| Gold | Eco-System Recycling Co., Ltd.* | Japan | ||
| Gold | Emirates Gold DMCC* | United Arab Emirates | ||
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India | ||
| Gold | Geib Refining Corporation* | United States Of America | ||
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd.* | China | ||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM* | China | ||
| 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 | ||
| 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 Uralelectromed* | Russian Federation | ||
| Gold | JX Nippon Mining & Metals Co., Ltd.* | Japan | ||
| Gold | Kazakhmys Smelting LLC | Kazakhstan | ||
| Gold | Kazzinc* | Kazakhstan | ||
| Gold | Kennecott Utah Copper LLC* | United States of America | ||
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland | ||
| Gold | Kojima Chemicals Co., Ltd.* | Japan | ||
| Gold | Korea Zinc Co., Ltd.* | Korea, Republic of | ||
| Gold | Kyrgyzaltyn JSC* | Kyrgyzstan | ||
| Gold | L’Orfebre S.A.* | Andorra | ||
| Gold | LS-NIKKO Copper Inc.* | Korea, Republic of | ||
| Gold | Marsam Metals* | Brazil | ||
| Gold | Materion* | United States of America | ||
| Gold | Matsuda Sangyo Co., Ltd.* | Japan | ||
| Gold | Metalor Technologies (Hong Kong) Ltd.* | China | ||
| Gold | Metalor Technologies (Singapore) Pte., Ltd.* | Singapore |
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Metal | Smelter or Refinery Facility Name† | Country† | ||
| Gold | Metalor Technologies (Suzhou) Ltd.* | China | ||
| Gold | Metalor Technologies S.A.* | Switzerland | ||
| Gold | Metalor USA Refining Corporation* | United States of America | ||
| Gold | MetalurgicaMet-Mex Penoles 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 | Moscow Special Alloys Processing Plant* | Russian Federation | ||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S.* | Turkey | ||
| Gold | Navoi Mining and Metallurgical Combinat* | Uzbekistan | ||
| Gold | Nihon Material Co., Ltd.* | Japan | ||
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | Austria | ||
| Gold | Ohura Precious Metal Industry Co., Ltd.* | Japan | ||
| Gold | OJSC “The Gulidov KrasnoyarskNon-Ferrous Metals Plant” (OJSC Krastsvetmet)* | Russian Federation | ||
| Gold | OJSC Novosibirsk Refinery* | Russian Federation | ||
| Gold | PAMP S.A.* | Switzerland | ||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China | ||
| Gold | Planta Recuperadora de Metales SpA* | Chile | ||
| Gold | Prioksky Plant ofNon-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 | REMONDIS PMR B.V.* | Netherlands | ||
| Gold | Royal Canadian Mint* | Canada | ||
| Gold | SAAMP* | France | ||
| Gold | Sabin Metal Corp. | United States of America | ||
| Gold | Safimet S.p.A* | Italy | ||
| Gold | Samduck Precious Metals* | Korea, Republic of | ||
| Gold | SAXONIA Edelmetalle GmbH* | Germany | ||
| 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 | Singway Technology Co., Ltd.* | Taiwan | ||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals* | Russian Federation | ||
| Gold | Solar Applied Materials Technology Corp.* | Taiwan | ||
| Gold | Sumitomo Metal Mining Co., Ltd.* | Japan | ||
| Gold | SungEel HiMetal Co., Ltd.* | 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 | TOOTau-Ken-Altyn | Kazakhstan | ||
| Gold | Torecom* | Korea, Republic of |
10
Metal | Smelter or Refinery Facility Name† | Country† | ||
| 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 of America | ||
| Gold | Valcambi S.A.* | Switzerland | ||
| Gold | Western Australian Mint (T/a The Perth Mint)* | Australia | ||
| Gold | WIELAND Edelmetalle GmbH* | Germany | ||
| Gold | Yamakin Co., Ltd.* | Japan | ||
| Gold | Yokohama Metal Co., Ltd.* | Japan | ||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | China | ||
| Tantalum | Asaka Riken Co., Ltd.* | Japan | ||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | China | ||
| Tantalum | D Block Metals, LLC* | United States of America | ||
| Tantalum | Exotech Inc.* | United States of America | ||
| 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 of America | ||
| Tantalum | Guangdong Rising RareMetals-EO Materials Ltd.* | China | ||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd.* | China | ||
| Tantalum | H.C. Starck Co., Ltd.* | Thailand | ||
| 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 | H.C. Starck Tantalum and Niobium GmbH* | 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 Janny New Material Co., Ltd.* | 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 of America | ||
| 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 | Ningxia Orient Tantalum Industry Co., Ltd.* | China | ||
| Tantalum | NPM Silmet AS* | Estonia | ||
| Tantalum | Power Resources Ltd.* | North Macedonia | ||
| Tantalum | QuantumClean* | United States of America | ||
| Tantalum | Resind Industria e Comercio Ltda.* | Brazil |
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Metal | Smelter or Refinery Facility Name† | Country† | ||
| 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 | XinXing HaoRong Electronic Material Co., Ltd.* | China | ||
| Tin | Alpha* | United States of America | ||
| Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam | ||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | China | ||
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd.* | China | ||
| Tin | China Tin Group Co., Ltd.* | China | ||
| Tin | CV Ayi Jaya* | Indonesia | ||
| Tin | CV Dua Sekawan* | Indonesia | ||
| Tin | CV Gita Pesona* | Indonesia | ||
| Tin | CV United Smelting* | Indonesia | ||
| Tin | CV Venus Inti Perkasa* | Indonesia | ||
| Tin | Dowa* | Japan | ||
| Tin | EM Vinto* | Bolivia | ||
| Tin | Estanho de Rondonia S.A. | Brazil | ||
| Tin | Fenix Metals* | Poland | ||
| Tin | Gejiu Fengming Metallurgy Chemical Plant* | China | ||
| Tin | Gejiu Kai Meng Industry and Trade LLC* | China | ||
| Tin | GejiuNon-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 HanheNon-Ferrous Metal Co., Ltd.* | 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 | 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 of America | ||
| Tin | Metallo Belgium N.V.* | Belgium | ||
| Tin | Metallo Spain S.L.U.* | Spain | ||
| Tin | Mineracao Taboca S.A.* | Brazil | ||
| Tin | Minsur* | Peru | ||
| Tin | Mitsubishi Materials Corporation* | Japan | ||
| Tin | Modeltech Sdn Bhd* | Malaysia | ||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | Thailand | ||
| Tin | O.M. Manufacturing Philippines, Inc.* | Philippines | ||
| Tin | Operaciones Metalurgicas S.A.* | Bolivia | ||
| Tin | PT Aries Kencana Sejahtera* | Indonesia | ||
| Tin | PT Artha Cipta Langgeng* | Indonesia |
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Metal | Smelter or Refinery Facility Name† | Country† | ||
| Tin | PT ATD Makmur Mandiri Jaya* | Indonesia | ||
| Tin | PT Babel Inti Perkasa* | Indonesia | ||
| Tin | PT Bangka Prima Tin* | Indonesia | ||
| Tin | PT Bangka Serumpun* | 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 Inti Stania Prima* | Indonesia | ||
| Tin | PT Karimun Mining* | Indonesia | ||
| Tin | PT Kijang Jaya Mandiri* | Indonesia | ||
| Tin | PT Menara Cipta Mulia* | Indonesia | ||
| Tin | PT Mitra Stania Prima* | Indonesia | ||
| Tin | PT Panca Mega Persada* | Indonesia | ||
| Tin | PT Premium Tin Indonesia* | Indonesia | ||
| Tin | PT Prima Timah Utama* | Indonesia | ||
| Tin | PT Rajehan Ariq* | 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 Tbk Kundur* | Indonesia | ||
| Tin | PT Timah Tbk Mentok* | Indonesia | ||
| Tin | PT Tinindo Inter Nusa* | Indonesia | ||
| Tin | PT Tommy Utama* | Indonesia | ||
| Tin | Resind Industria e Comercio Ltda.* | Brazil | ||
| Tin | Rui Da Hung* | Taiwan | ||
| Tin | Soft Metais Ltda.* | Brazil | ||
| Tin | Thaisarco* | Thailand | ||
| Tin | White Solder Metalurgia e Mineracao Ltda.* | Brazil | ||
| Tin | Yunnan ChengfengNon-ferrous Metals Co., Ltd.* | China | ||
| Tin | Yunnan Tin Company Limited* | China | ||
| Tungsten | A.L.M.T. Corp.* | Japan | ||
| 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 Co., Ltd.* | China | ||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd.* | China | ||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | China | ||
| Tungsten | Global Tungsten & Powders Corp.* | United States of America | ||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | China | ||
| Tungsten | H.C. Starck Smelting GmbH & Co. KG* | Germany | ||
| Tungsten | H.C. Starck Tungsten GmbH* | Germany | ||
| Tungsten | Hunan Chenzhou Mining Co., Ltd.* | China |
13
Metal | Smelter or Refinery Facility Name† | Country† | ||
| Tungsten | Hunan Chunchang Nonferrous Metals 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 Gan Bei Tungsten Co., Ltd.* | China | ||
| Tungsten | Jiangxi TongguNon-ferrous Metallurgical & Chemical Co., Ltd.* | China | ||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | China | ||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | China | ||
| Tungsten | Kennametal Huntsville* | United States of America | ||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | China | ||
| Tungsten | Masan Tungsten Chemical LLC (MTC)* | Vietnam | ||
| Tungsten | Niagara Refining LLC* | United States of America | ||
| Tungsten | Philippine Chuangxin Industrial Co., Inc.* | Philippines | ||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City* | China | ||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* | Vietnam | ||
| Tungsten | Wolfram Bergbau und Hutten AG* | Austria | ||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | China | ||
| Tungsten | Xiamen Tungsten Co., Ltd.* | China | ||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | China | ||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | China |
| † | Smelter and refiner facility names and locations as reported by the RMI as of March 1, 2019. |
| * | Denotes smelters and refiners which are conformant to a responsible mineral sourcing validation program as of March 1, 2019. |
| ** | Denotes smelters and refiners which are participating in a responsible mineral sourcing validation program as of March 1, 2019. |
Product Conclusions
For this reporting period, we identified the following products which we manufactured or contracted with others to manufacture that may contain necessary conflict minerals. On the basis of our due diligence measures as described in this Report as of March 1, 2019, we have made the following conclusions in good faith for this reporting period.
OurMicroprocessors, FPGA Products and Chipsets Solely Manufactured by Intelconsisting of Celeron®, Pentium®, Intel® Core™, Intel® Xeon®, Intel® Quark™ and Intel Atom® processors; Intel® Stratix®, Intel® Arria®, and Intel® Cyclone® FPGAs; Intel® MAX® CPLD; Intel® Enpirion® Power Solutions and Mobileye EyeQ* family ofsystem-on-chip (SoC) devices: All surveyed suppliers which we identified as contributing necessary conflict minerals to these products have identified the smelters and refiners in the supply chain that are the sources of the necessary conflict minerals, and all of these smelters and refiners are conformant to a responsible mineral sourcing validation program. We have therefore reasonably concluded that these necessary conflict minerals did not directly or indirectly finance or benefit armed groups in the Covered Countries based on our due diligence measures performed.
OurOther Products consisting of other server products and networking, boards and kits, memory storage products, and other Mobileye products: With the exception of six Mobileye-unique suppliers with whom our due diligence is ongoing as described above, all of the surveyed suppliers which we identified as contributing necessary conflict minerals to these products provided a CMRT in response to our supply chain survey request. Of these surveyed suppliers, 96% were in compliance with our conflict minerals policy or contractual requirements. All of the smelters and refiners identified by these surveyed suppliers were either conformant to a responsible mineral sourcing validation program, have begun participating in such a program, or are facilities that, based on our own due diligence activities, we have reasonably concluded do not process conflict minerals which originated from the Covered Countries. We have no reason to believe the necessary conflict minerals in ourOther Products directly or indirectly finance or benefit armed groups in the Covered Countries based on our due diligence measures performed.
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Our efforts to determine the mine or location of origin of the necessary conflict minerals in all of our products with the greatest possible specificity consisted of the due diligence measures described in this Report. In particular, we relied on the information made available by responsible mineral sourcing validation programs for the smelters and refiners in our supply chain because such programs review and audit whether sufficient evidence exists regarding the mine and/or location of origin of the conflict minerals that the audited smelter or refiner facilities have processed. We also sought source and chain of custody information directly from smelters and refiners and from publicly available sources and, if we determined such information to be reliable, we used the information to make reasonable conclusions on the source and chain of custody of the conflict minerals processed by facilities which were not conformant to or participating in a responsible mineral sourcing validation program.
Future Due Diligence Measures
During the reporting period for the calendar year ending December 31, 2019, we are continuing to engage in the activities described above in “Design of Conflict Minerals Program.” We intend to continue to contact smelters and refiners identified in our supply chain survey process that are not yet conformant to a responsible mineral sourcing validation program and request their participation in such a program, supporting our efforts to build ethical and socially responsible supply chains for our company.
Additionally, Intel’s responsible minerals program is evolving to address a broader range of minerals originating from Conflict-Affected and High-Risk Areas (CAHRAs), as defined by the OECD Guidance. We are assessing the risks of other minerals in our products and updating our due diligence practices to address CAHRAs when conducting country of origin analysis in our supply chain. We also have updated our minerals sourcing policy to reflect this expansion in scope. One example of this expansion effort is our integration of cobalt into our responsible minerals program by surveying our direct suppliers to identify cobalt refiners in our microprocessor supply chain. We then conduct due diligence on the identified refineries and actively focus our outreach efforts to onboard them into the RMAP. Participation in such a program verifies these facilities have management systems in place to ensure the cobalt they process is responsibly sourced. Additionally, Intel is participating in developing industry-wide standards to better align, and thus strengthen, the collective approach to responsible cobalt sourcing. Intel is continuing to partner with the RMI and other key industry associations to expand and improve all aspects of responsible mineral sourcing.
Independent Private Sector Audit of this Report
We obtained an independent private sector audit of this Report by Ernst & Young LLP, which is set forth as Exhibit A to this Report.
Intel and the Intel logo, Intel Atom, Intel Core, Xeon, Celeron, Pentium, Quark, Stratix, Arria, Cyclone, MAX, and Enpirion are trademarks of Intel Corporation or its subsidiaries in the U.S. and/or other countries.
| * | Other names and brands may be claimed as the property of others. |
15
Exhibit A
Report of Independent Accountants
To the stockholders and The Board of Directors of Intel Corporation
We have examined whether the design of Intel Corporation’s (the “Company”) due diligence framework as set forth in the Design of Conflict Minerals Program section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2018, is in conformity, in all material respects, with the criteria set forth in the Organisation of EconomicCo-Operation and DevelopmentDue Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition 2016, (“OECD Due Diligence Guidance”), and whether the Company’s description of the due diligence measures it performed, as set forth in Description of Due Diligence Measures Performed section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2018, is consistent, in all material respects, with the due diligence process that the Company undertook.
Management is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. Our responsibility is to express an opinion on the design of the Company’s due diligence framework and on the description of the due diligence measures the Company performed, based on our examination. Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards applicable to attestation engagements contained inGovernment Auditing Standards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our opinion. Our examination was not conducted for the purpose of evaluating:
| • | The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance |
| • | The completeness of the Company’s description of the due diligence measures performed |
| • | The suitability of the design or operating effectiveness of the Company’s due diligence process |
| • | Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance |
| • | The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof |
| • | The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products |
Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than the design of the Company’s due diligence framework as set forth in the Design of Conflict Minerals Program section and the Company’s description of the due diligence measures it performed as set forth in the Description of Due Diligence Measures Performed section referenced in the first paragraph above.
In our opinion, the design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2018, as set forth in the Design of Conflict Minerals Program section of the Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and the Company’s description of the due diligence measures it performed as set forth in the Description of Due Diligence Measures Performed section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2018, is consistent, in all material respects, with the due diligence process that the Company undertook.
/s/ Ernst & Young LLP
San Jose, California
May 16, 2019