PLANTRONICS, INC.
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2015
Introduction
This Conflict Minerals Report for the calendar year ended December 31, 2015 (“CY 2015”) is presented by Plantronics, Inc. (“we” or the “Company”) to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Exchange Act”).
Plantronics is a global company that manufactures and contracts to manufacture communications headsets and related equipment, as listed on our Form SD of which this report is a part, from a global supply chain with many levels. We work with our supplier base to identify the facilities processing Tin, Tantalum, Tungsten and Gold (3TG) in our supply chain.
As part of the RCOI described in Form SD, Plantronics performed a supplier survey using the Conflict Free Sourcing Initiative (CFSI) Conflict Minerals Reporting Template (CMRT) during the second half of CY 2015. All 78 direct suppliers providing components used in Plantronics products within scope of the rule as described further in the Form SD) were included in the survey utilized for both RCOI and Due Diligence. The information obtained in the survey indicated that there was reason to believe that a portion of the 3TG used in Plantronics products may have originated in the Democratic Republic of Congo or the adjoining countries (the “covered countries”) and were not exclusively from scrap or recycled sources, triggering the due diligence steps described in the following sections.
Design and Execution of Due Diligence
We designed and implemented the majority of our due diligence measures prior to the current reporting year CY 2015. These measures were continued in CY 2015 and are described herein. They are designed to conform, in all material respects, to the framework in The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD 2012) including the Supplement on Tin, Tantalum and Tungsten, as well as those portions of the OECD Supplement on Gold applicable to downstream companies (collectively the “OECD Guidance”). In accordance with the five step OECD Guidance, our measures are designed to determine, to the best of our ability, the source and chain of custody of the 3TG materials necessary for the functionality and/or production of our products, to ascertain if the materials originated in one of the covered countries, and if so, whether armed groups directly or indirectly benefited as a result.
1.Establish Strong Company Management Systems
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| • | Plantronics has a company Conflict Minerals team consisting of representatives from the Engineering Compliance, Legal, Operations/Materials, Quality and Supplier Quality Engineering departments. |
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| • | Plantronics has a conflict minerals policy statement publicly available at http://www.plantronics.com/us/company/global-citizenship/#section5. |
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| • | We maintain a grievance reporting system open to both employees and suppliers through our ethics reporting system at http://www.plantronics.com/us/company/global-citizenship/#section5. |
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| • | In addition to any annual survey using the CMRT, supplier obligations and requirements in this regard have been incorporated into the Supplier Code of Conduct, which is available on the corporate governance section of our website. In addition, Conflict Minerals Requirements, including due diligence and participation in annual supplier survey, are included in our controlled “Purchasing & Supplier Management” methods and procedures document. |
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| • | Plantronics purchase orders and contracts include a supplier Conflict Minerals Due Diligence expectations clause. |
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| • | Plantronics establishes and maintains long term relationships with the majority of our first tier Original Design, Contract, and Custom Part Manufacturers to facilitate engagement with suppliers to improve due diligence performance. |
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| • | Since we have limited direct relationships with any facilities processing 3TG, we are an active participant in the Conflict Free Sourcing Initiative (CFSI) (http://www.conflictfreesourcing.org/about/members-and-collaborations/) to aid the development of conflict free supply chains at the smelter or refiner level and further upstream. |
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| • | Conflict Minerals materials records are maintained pursuant to our records retention policy. |
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| • | The Conflict Minerals Team issues a formal report of progress and findings to upper management quarterly. |
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| • | We created a controlled Methods and Procedures document regarding Conflict Minerals Due Diligence Procedures. |
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| • | For CY2014 we purchased and installed a software tool to improve management and auditability of supplier communications, as well as to receive, evaluate, store, and determine statistics on incoming CMRTs which we continued to use in CY 2015. |
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| • | Starting in CY 2015 our supplier quality team conducted audits of selected first tier suppliers’ conflict minerals due diligence programs. These audits assessed policy, training, record retention and data validation. Eight such audits were performed in 2015, three audits resulted in supplier corrective action plans, all of which were successfully completed. |
2.Identified and Assessed Risk in the Supply Chain
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| • | We conducted a supplier survey of the 78 direct first tier suppliers providing products or components within scope of the rule; necessary for the functionality of our products and likely to contain 3TG. Prior to conducting the survey we conducted one-on-one training with selected critical suppliers in Asia, either in person or by web. The survey required that the supplier return the then current version of the CMRT (4.0x). Our request included information to inform the suppliers of Plantronics’ Conflict Minerals Rule reporting obligations as well as the assistance required from our supply chain, and the resulting expectations for the sourcing of conflict minerals. A link to the Plantronics’ Conflict Minerals policy was included in the request. |
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| • | Reminders, late notices and finally delinquent notices were sent to non-responsive suppliers. Commodity Managers were involved in escalation at the time of the delinquent notices. We did not find it necessary to restrict business or disengage from any supplier due to failure to respond to the survey. |
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| • | All incoming CMRTs underwent a two-step review process. The first step is a PASS/FAIL check by our Conflict Minerals software for completeness and internal consistency of the declaration and submitted smelter list. A message was automatically sent by the system to suppliers submitting CMRTs containing errors with an explanation of the error and a request for corrective action and re-submission. |
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| • | Once CMRTs passed this first evaluation, they were then evaluated by internal compliance engineers on an ACCEPT/MODIFY basis for consistency with the known content and complexity of the products or components provided. A message was sent to suppliers submitting CMRTs found insufficient or incomplete with an explanation and request for corrective action. We continued to communicate with those suppliers to improve the content and quality of their responses. 100% of the suppliers responded by returning a CMRT, and eventually 97% of the responses were accepted. |
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| • | In addition, we used a data mining service to obtain conflict minerals information, also using the CFSI CMRT, from manufacturers of off-the-shelf components with whom we had no direct relationship. |
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| • | Facilities processing 3TG reported by the supply chain were categorized, based on information available through CFSI, as |
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| ◦ | Legitimate Smelters or Refiners (“SORs”), |
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| ◦ | Entities known to Not be legitimate SORs. |
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| • | In addition to SORs known to, or believed to, source from the covered countries who were not validated as conflict free, Plantronics identified non-smelters as a source of risk, since the actual source of the 3TG is not known. |
3.Designed and Implemented a Strategy to Respond to Identified Risks
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| • | We have continuously conducted research into “alleged” SORs - companies reported that were not on any list of known SORs- reported in our supplier survey to determine the nature of these entities’ business. This effort is done both through collaborative efforts in CFSI, and our own independent research in areas where we have associates that speak the local language. Through these efforts the final number of “alleged” SORs has been significantly reduced progressively from the number in previous reporting years, from 83 in CY2013 to 46 in CY2014 to none in the final CY 2015 survey results. This is attributable to determining that many of the alleged SORs were indeed legitimate SORs or legitimate SOR aliases, or determination of the company’s actual business, as well as improved supplier reporting. |
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| • | We also asked suppliers initially reporting non-smelters or alleged smelters to verify the information and if possible, identify actual smelters. We gave feedback concerning the actual nature of a non-smelter’s business to the supplier when such information was available, primarily through CFSI collaborative efforts. |
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| • | We continued to work within CFSI teams to determine the legitimacy of any “alleged SORs” reported by our supply chain. We encouraged known smelters not yet validated as Conflict Free to participate in Conflict Free Smelter Program (CFSP). |
4.Carry out independent 3rd Party Audit of Smelters’/Refiners’ Due Diligence Practices
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| • | Because Plantronics has few direct business relationships with smelters, we worked within industry initiatives to implement validation of DRC conflict free smelters as outlined in OECD Guidance for downstream companies. We relied on the results of audits conducted by CFSP to determine smelters’ Due Diligence Practices. As an active contributing member of the CFSI, we actively participated in outreach to confirmed smelters to encourage participation in CFSP. |
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| • | A Plantronics associate acted as a single point of contact to directly help two smelters prepare for the CFSP audit. |
5.Report Annually on Supply Chain Due Diligence
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| • | Our Form SD and this Report together constitute our annual report on our Conflict Minerals Due Diligence. These have been filed with the SEC and are available on our website at http://www.plantronics.com/us/company/global-citizenship/#section5. |
Results of due diligence performed
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| • | Most of our direct supplier responses represented their supply chain at a company-level rather than being product-specific. Therefore, the list of processing facilities contained in this report may contain more facilities than those that actually process the conflict minerals contained in our products. The total number of unique entities reported as smelters or refiners by the Plantronics supplier base as result of CY 2015 Supplier Survey was 299. Of these, 279 have been confirmed as being legitimate SORs by the CFSI, 20 are known to not be legitimate SORs, and there were no reported entities whose status could not be confirmed as of our cutoff date of April 15, 2016. |
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| • | Of the 279 legitimate SORs reported by the supplier base, 210 had been validated by CFSP as being in conformance with a CFSP recognized conflict free audit protocol (CFSP, London Bullion Market Association, or Responsible Jewelry Council). Another 46 were in process or communication with CFSP, or participating in another recognized program, but had not achieved validated status as of April 30, 2016. |
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| • | The twenty entities reported by our supply chain that are not legitimate smelters fell into three categories: companies that are group companies with a number of legitimate smelter locations (9), formerly legitimate smelters that had either temporarily or permanently suspended operations (4) or companies downstream of the actual smelter (7). |
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| • | The remaining legitimate smelters require outreach to encourage participation in a conflict free program. Plantronics actively participates in CFSI targeted outreach through email and, in countries where we have associates that speak the local language, telephone calls. We have also begun to interact directly with selected smelters to help guide them through the CFSP audit process. |
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| • | Of the 279 legitimate SORs reported by the supplier base, we determined during RCOI that there was no reason to believe that 136 of the SORs sourced or may have sourced any minerals from the covered countries. |
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| • | Of the remaining smelters with definitive RCOI information available through CFSI or other publicly available information, 19 were known or reasonably believed to source minerals from the DRC, the surrounding countries or countries known as possible routes for smuggling or export of minerals out of the DRC. All 19 are CFSP validated. The facilities not eliminated during RCOI, along with the location of the facility and the conflict free status are listed in Table I. The countries believed to be the source of 3TG in our products are listed in Table II. |
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| • | While we did not find any information that would give us reason to believe armed groups directly or indirectly benefitted as a result of the mining, transport for processing of 3TG in our products, the smelter information collected from our suppler base included non-smelters as well as a number of legitimate smelters or refiners that had not been audited and validated as DRC Conflict Free by the CFSP, or any other recognized organization. For these reasons, we are unable to determine that any of our products or product categories are DRC Conflict Free. |
Steps to be taken to further mitigate risk
We intend to continue taking the following steps to build on momentum established in the past two years to improve the due diligence conducted, and to further mitigate the risk that the necessary conflict minerals in our products benefit armed groups in the Covered Countries:
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| • | Improve the accuracy of our smelter list by requesting that the suppliers providing Parent companies of SORs determine which smelter site is involved, verify that materials from smelters that have ceased operations are still in their supply chain, and try to obtain smelter information from downstream companies named on their CMRT. |
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| • | Try to increase the number of off-the-shelf part manufacturers from whom conflict minerals data is obtained. |
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| • | Maintain membership and active participation within CFSI, conducting research into smelter operations, sourcing and compliance. Continue to conduct coordinated outreach to encourage more smelters to participate in recognized conflict free validation programs such as the Conflict Free Smelter Program. |
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| • | Continue to engage directly with selected smelters to help guide them through the CFSP audit process. |
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| • | Encourage our supply chain to use validated conflict free smelters, in particular those sourcing responsibly within the DRC and adjoining countries, to the greatest extent possible. |
Table I. Plantronics Smelter List
List and status of SORs are as of April 30, 2016 and status data is from CFSI. The list includes 143 recognized SORs that are either known to obtain at least some minerals from the covered countries or are SORs where the source of the minerals was not disclosed and could not be determined. It does not include those SORs that source only from outside the covered countries as determined through RCOI, or process only recycled or scrap materials. “Country” refers to the location of the facility, not the source of minerals. The smelter location was not used for RCOI, since it does not necessarily determine the source of the ore, although location near abundant mineral resources can be an indicator of mineral sourcing. The general geographical breakdown of all the reported smelters is as follows:
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| Region | Number |
| Asia | 175 |
| Europe | 36 |
| North America | 31 |
| South America | 16 |
| Russia and Central Asia | 15 |
| Middle East | 4 |
| Africa | 2 |
Status is defined as:
Compliant: Smelters or refiners that have been audited and have been validated as compliant with the Conflict-Free Smelter Program or cross recognized (LBMA, RJC) assessment protocols.
Not Validated: Legitimate Smelters or refiners who have not yet completed a CFSP or cross recognized audit validating a conflict free process.
CFSP Active: Smelters and refiners on the Active list have committed to undergo a CFSP audit.
Status data from CFSI as of April 30, 2016:
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| Metal | Smelter Name | Country | CFSI Smelter ID | Conflict Free Status |
| Gold | Advanced Chemical Company | UNITED STATES | CID000015 | CFSP Active |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 | Compliant |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 | CFSP Active |
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | CID000058 | Compliant |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 | Compliant |
| Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 | Compliant |
| Gold | Asahi Refining USA Inc. | UNITED STATES | CID000920 | Compliant |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 | Compliant |
| Gold | Aurubis AG | GERMANY | CID000113 | Compliant |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 | Compliant |
| Gold | Boliden AB | SWEDEN | CID000157 | Compliant |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 | Compliant |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 | Compliant |
| Gold | Cendres + Métaux S.A. | SWITZERLAND | CID000189 | CFSP Active |
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| Metal | Smelter Name | Country | CFSI Smelter ID | Conflict Free Status |
| Gold | Chimet S.p.A. | ITALY | CID000233 | Compliant |
| Gold | Chugai Mining | JAPAN | CID000264 | Not Validated |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 | CFSP Active |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 | Not Validated |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 | CFSP Active |
| Gold | Faggi Enrico S.p.A. | ITALY | CID002355 | CFSP Active |
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | CID000522 | Not Validated |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 | Not Validated |
| Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 | Not Validated |
| Gold | Heraeus Ltd. Hong Kong | CHINA | CID000707 | Compliant |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 | Compliant |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 | Not Validated |
| Gold | Hwasung CJ Co., Ltd. | KOREA, REPUBLIC OF | CID000778 | Not Validated |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 | Not Validated |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 | Compliant |
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 | Compliant |
| Gold | Japan Mint | JAPAN | CID000823 | Compliant |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 | Compliant |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 | Compliant |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 | Compliant |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 | Compliant |
| Gold | Kazzinc | KAZAKHSTAN | CID000957 | Compliant |
| Gold | Kennecott Utah Copper LLC | UNITED STATES | CID000969 | Compliant |
| Gold | Korea Metal Co., Ltd. | KOREA, REPUBLIC OF | CID000988 | Not Validated |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 | Not Validated |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 | Not Validated |
| Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 | Not Validated |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 | Not Validated |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 | Compliant |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 | Not Validated |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 | Compliant |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 | Compliant |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 | Compliant |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 | CFSP Active |
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| Metal | Smelter Name | Country | CFSI Smelter ID | Conflict Free Status |
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 | Compliant |
| Gold | Metalor USA Refining Corporation | UNITED STATES | CID001157 | Compliant |
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | CID001161 | Compliant |
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 | Compliant |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 | Compliant |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 | Compliant |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 | Compliant |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.?. | TURKEY | CID001220 | Compliant |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 | CFSP Active |
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 | Compliant |
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 | Compliant |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 | Compliant |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 | Compliant |
| Gold | PAMP S.A. | SWITZERLAND | CID001352 | Compliant |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 | Not Validated |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 | Compliant |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 | Compliant |
| Gold | PX Précinox S.A. | SWITZERLAND | CID001498 | Compliant |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 | Compliant |
| Gold | Republic Metals Corporation | UNITED STATES | CID002510 | Compliant |
| Gold | Royal Canadian Mint | CANADA | CID001534 | Compliant |
| Gold | Sabin Metal Corp. | UNITED STATES | CID001546 | Not Validated |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 | CFSP Active |
| Gold | SAMWON Metals Corp. | KOREA, REPUBLIC OF | CID001562 | Not Validated |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 | CFSP Active |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | CID001573 | Compliant |
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | CID001585 | Compliant |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 | Not Validated |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 | Compliant |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 | Compliant |
| Gold | So Accurate Group, Inc. | UNITED STATES | CID001754 | Not Validated |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 | Compliant |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 | Compliant |
| Gold | T.C.A S.p.A | ITALY | CID002580 | Compliant |
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| Metal | Smelter Name | Country | CFSI Smelter ID | Conflict Free Status |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 | Compliant |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 | Compliant |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 | Compliant |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 | Not Validated |
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 | CFSP Active |
| Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 | Compliant |
| Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 | Compliant |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 | Compliant |
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 | Compliant |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | CID002030 | Compliant |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 | CFSP Active |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 | Not Validated |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 | Compliant |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | CID002243 | Compliant |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | CID000291 | Compliant |
| Tantalum | Duoluoshan | CHINA | CID000410 | Compliant |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 | Compliant |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES | CID002557 | Compliant |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 | Compliant |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | CID002545 | Compliant |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | CID002546 | Compliant |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 | Compliant |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 | Compliant |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 | Compliant |
| Tantalum | KEMET Blue Metals | MEXICO | CID002539 | Compliant |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 | Compliant |
| Tantalum | Mitsui Mining & Smelting | JAPAN | CID001192 | Compliant |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 | Compliant |
| Tantalum | Taki Chemicals | JAPAN | CID001869 | Compliant |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 | Compliant |
| Tantalum | Zhuzhou Cemented Carbide | CHINA | CID002232 | Compliant |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 | CFSP Active |
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | CID000278 | Not Validated |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC | VIET NAM | CID002572 | CFSP Active |
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| Metal | Smelter Name | Country | CFSI Smelter ID | Conflict Free Status |
| Tin | Estanho de Rondônia S.A. | BRAZIL | CID000448 | Not Validated |
| Tin | Feinhütte Halsbrücke GmbH | GERMANY | CID000466 | CFSP Active |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 | CFSP Active |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 | Not Validated |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 | Not Validated |
| Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CHINA | CID001063 | Not Validated |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 | Compliant |
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | CID001231 | Not Validated |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 | CFSP Active |
| Tin | Phoenix Metal Ltd. | RWANDA | CID002507 | CFSP Active |
| Tin | PT Alam Lestari Kencana | INDONESIA | CID001393 | Not Validated |
| Tin | PT Bangka Kudai Tin | INDONESIA | CID001409 | Not Validated |
| Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | CID001416 | Not Validated |
| Tin | PT Fang Di MulTindo | INDONESIA | CID001442 | Not Validated |
| Tin | PT Karimun Mining | INDONESIA | CID001448 | CFSP Active |
| Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | CID001486 | Not Validated |
| Tin | PT Seirama Tin Investment | INDONESIA | CID001466 | Not Validated |
| Tin | Thaisarco | THAILAND | CID001898 | Compliant |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 | CFSP Active |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 | CFSP Active |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 | Compliant |
| Tungsten | Ganxian Shirui New Material Co., Ltd. | CHINA | CID002531 | Not Validated |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 | Not Validated |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | VIET NAM | CID002538 | CFSP Active |
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | CID002011 | Compliant |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | CID002044 | Compliant |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 | Compliant |
Table II. The Countries of Origin for the minerals present in Plantronics products are believed to potentially include, but may not be limited to the following. Information is from smelters, news reports, industry associations, metals brokers’ reports, and USGS reports (Countries listed for 3T are reported to account for ~98% of global mined ore):
Tungsten: China, Vietnam, Russia, Canada, Bolivia, Rwanda, Austria, Spain, Portugal, United Kingdom, Republic of Korea, Untied States, DRC
Tantalum: Rwanda, DRC, Brazil, Mozambique, Chain, Nigeria, Ethiopia, Burundi, Canada, Australia, Uganda
Tin: China, Indonesia, Myanmar, Peru, Bolivia, Brazil, DRC, Australia, Malaysia, Nigeria, Russia, Rwanda, Thailand, Vietnam, Russia, Portugal
Gold: China, Australia, Russia, United States, Peru, Canada, South Africa, Mexico, Uzbekistan, Ghana, Brazil, Papua New Guinea; DRC, Kazakhstan, Argentina, Tanzania, Mali, Dominican Republic, Columbia, Philippines Chile, Burkina Faso, Ivory Coast, Mongolia, Turkey, Guinea
