1.01 05312019

This Conflict Minerals Report for the year ended December 31, 2018 (this “Report”) is intended to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission registrants whose manufactured products contain “conflict minerals” which are necessary to the functionality or production of their products. Conflict minerals are defined as cassiterite, columbite-tantalite, gold, wolframite, and their derivatives, which are limited to tin, tantalum, tungsten, and gold (“3TG”).

Unless otherwise specified, the terms “we,” “us,” “our,” “FCA,” and the “Company” refer to Fiat Chrysler Automobiles N.V., a public limited liability company (naamloze vennootschap) organized under the laws of the Netherlands, together with its consolidated subsidiaries or any one or more of them, as the context may require.

We are a global automotive group engaged in designing, engineering, manufacturing, distributing and selling vehicles, components and production systems worldwide through 102 manufacturing facilities and 46 research and development centers. We have operations in more than 40 countries and sell our vehicles directly or through distributors and dealers in more than 135 countries. We design, engineer, manufacture, distribute and sell vehicles for the mass-market under the Abarth, Alfa Romeo, Chrysler, Dodge, Fiat, Fiat Professional, Jeep, Lancia and Ram brands, and the SRT performance vehicle designation. For our mass-market vehicle brands, we have centralized design, engineering, development and manufacturing operations, which allow us to efficiently operate on a global scale. We support our vehicle shipments with the sale of related service parts and accessories, as well as service contracts, worldwide under the Mopar brand name for mass-market vehicles. In addition, we design, engineer, manufacture, distribute and sell luxury vehicles under the Maserati brand. We make available retail and dealer financing, leasing and rental services through our subsidiaries, joint ventures and commercial arrangements with third party financial institutions. In addition, we operate in the components and production systems sectors under the Teksid and Comau brands.

For the reporting period from January 1 to December 31, 2018, we conducted due diligence on the source and chain of custody of the 3TG necessary to the production of the products that we manufactured or contracted to manufacture. Our resulting reasonable country of origin inquiry concluded that 3TG in our products may have originated in the Democratic Republic of the Congo (the “DRC”), and adjoining countries (with the DRC, the “Covered Countries”) and are not from recycled or scrap sources.

We have a global supply chain and, as a result, many of our direct suppliers’ manufacturing operations are located outside of the U.S. and include entities not directly subject to the Rule. Additionally, we did not directly source 3TG from a smelter in 2018. Accordingly, we rely on our direct suppliers to provide information as to the origin of the 3TG contained in the parts and components supplied to us and we are subject to the accuracy of those responses.

Our RCOI employed a combination of measures to determine whether the 3TG in our products originated from the Covered Countries or came from recycled or scrap sources. Our primary means of determining country of origin of 3TG was by conducting a survey of our direct production, service, and after-market part suppliers using the Responsible Minerals Initiatives (“RMI”) Conflict Minerals Reporting Template (“CMRT”) and the iPoint Conflict Minerals Platform (“iPCMP”).

As outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third Edition guidelines (“OECD Guidance”), the internationally recognized standard on which our system is based. We support an industry-wide approach to addressing conflict minerals throughout the supply chain. As part of this approach, we collaborate with others in the industry through its participation in the RMI, formerly known as the Conflict-Free Sourcing Initiative. We relied on data obtained through our membership in the RMI (member ID: FCAG) for certain statements in this declaration.



1.	establish strong company management systems;
2.	identify and assess conflict mineral risks in our supply chain;
3.	design and implement strategies to respond to identified conflict mineral risks;
4.	contribute to independent third-party audits of the due diligence practices of 3TG smelters and refiners by participating in industry organizations; and
5.	report annually on supply chain due diligence.

FCA is firmly convinced that the respect and support of fundamental human rights is essential for building a better future for our Company and the communities in which we do business. This belief is expressed in the FCA Human Rights Guidelines, which the Group promotes within its sphere of influence, expecting its suppliers, contractors and other business partners to adhere to these standards.

To support this conviction, FCA is committed to responsible sourcing and avoids knowingly using minerals that may be linked to human rights abuses. This commitment includes Conflict Minerals, currently designated as tin, tungsten, tantalum and gold (3TG) from conflict-affected and high risk areas.

We seek to avoid knowingly using Conflict Minerals from sources that support or fund inhumane treatment of workers, including human trafficking, slavery, forced labor, child labor, torture and war crimes. FCA reports annually to applicable government agencies regarding Conflict Minerals.

Our direct suppliers are requested to complete the FCA Conflict Minerals Reporting Template to report their use of 3TG, the processing smelter or refiner, and the country and mine of origin. FCA direct suppliers are expected to request necessary Conflict Minerals information from their own supply chain. If a supplier’s response indicates that its products do not include 3TG, the supplier must certify this information.

As a member of the Responsible Minerals Initiative, we also leverage due diligence conducted by the Conflict-Free Smelter Program (CFSP).(*) The CFSP uses third-party auditors to ensure that participating smelters and refiners are properly identifying their chain of custody and source of 3TG. A smelter or refiner is found to be CFSP-compliant if an independent auditor has verified that the smelter or refiner’s 3TG originated from conflict free mines and trading.

For the reporting of alleged violations, FCA has dedicated channels to provide a common, worldwide and independent intake via telephone and web. The FCA Ethics Helpline website provides country-specific instructions on how to report potential forms of misconduct. It can be found at this link: https://secure.ethicspoint.eu/domain/media/en/gui/102375/index.html.

In addition to a conflict minerals compliance program led by our purchasing department, a cross-functional conflict minerals oversight committee provides expertise and feedback. A designated conflict minerals champion leads our conflict minerals oversight committee and each of our regions and affiliates has designated a conflict minerals team lead to ensure engagement. Our conflict minerals working group includes representatives from supplier relations, materials engineering, legal, sustainability, communications and purchasing.

We are also an active participant in the Automotive Industry Action Group (“AIAG”), an industry association of original equipment manufacturers (“OEMs”) and large suppliers, and are a member of various AIAG work groups, and sub-groups including the responsible materials work group, that meet regularly to facilitate comprehensive and efficient compliance with conflict minerals regulation. Additionally, we are an active member of the RMI, an industry program that helps manage risk by improving supply chain transparency with regard to conflict minerals. Both the AIAG and RMI are actively involved with auditing and validating the conformance of OECD Guidance of smelters and refiners.

We did not have a direct relationship in 2018 with any of the smelters and refiners of the 3TG in our products. As a result, we have continued to take actions to improve transparency in our supply chain through industry initiative participation with RMI and certain other cross industry collaboration groups.

The control systems we have in place include, but are not limited to, a dedicated e-mail address for conflict minerals information, supplier response retention in the iPCMP and a smelter outreach program through AIAG and RMI. We also use the “CM3” document through AIAG, which lays out procedures across the automotive sector for a uniform central system to implement 3TG supply chain compliance.

In 2018, we organized conflict minerals training classes in Shanghai, China, Turin, Italy and Auburn Hills, Michigan for our suppliers. These trainings include instructions to suppliers regarding development of their own conflict minerals compliance program, the process for properly responding to the CMRT, and methods for engagement with their own supply base.

We have actively participated in the continuing development of AIAG training materials for the automotive supply base, including the development of industry criteria for assessing supplier responses. Additionally, as participants in AIAG we continued to survey our supply chain and, with the help of experts, analyze the data to determine where we can best support more efficient and effective reporting. Finally, through the AIAG’s Smelter Engagement Team, we encouraged smelters to join the Responsible Minerals Assurance Process (“RMAP”).

In addition to the due diligence processes discussed above, we used the iPCMP, a web-based reporting tool developed in partnership with AIAG, and CMRT tools to ask our direct suppliers to report their use of 3TG, the processing smelter or refiner and the country and mine of origin. If a supplier’s response indicated that its products do not include 3TG, we asked the supplier to confirm this information.

We work closely with other OEMs and large suppliers as active members of the AIAG and RMI. In addition, we are financial supporters of the RMI and the AIAG responsible materials work group. The AIAG conflict minerals work group was formed to bring together suppliers, OEMs and service providers to understand the impact of the Rule and support implementation across the automotive supply chain. We are also actively engaged in the RMI due diligence committee and RMAP. RMAP takes a unique approach to helping companies make informed choices about responsibly sourced minerals in their supply chains. We also co-chair the AIAG smelter engagement team, which conducts outreach encouraging smelters to participate in smelter audits.

We have a two-pronged strategy for responding to identified risks in our supply chain. First, our policy statement, discussed above, promotes responsible sourcing from the Covered Countries. Second, while we request that all direct suppliers respond to the survey, we targeted “high-priority” suppliers representing a significant majority of our procurement activities and have an internal escalation process to ensure responses from these high-priority suppliers. Additionally, our standard terms and conditions impose a specific duty on our suppliers to provide information regarding the smelters in their supply chain.

As stated above, we are active financial supporters of RMI and we support the RMAP, which performs independent third-party audits of smelters and refiners. We do not have a direct relationship with 3TG smelters or refiners and do not perform or direct audits of these entities within our supply chain.

Survey responses were reviewed against AIAG criteria and our processes to identify necessary further engagement with our suppliers. We have also worked directly with suppliers to obtain accurate and complete responses. However, our survey process continued to face various fundamental challenges.

Second, although our efforts in 2018 continued to focus on reducing the number of duplicates and obtaining high quality responses, supplier responses continue to include non-conformant smelters, numerous duplicate smelters or refiners or named companies that are not smelters or refiners.

Third, the vast majority of supplier responses received provided data at a company or divisional level. As a result, we cannot be certain that the smelter or refiner names provided by a direct supplier, to the extent they are actual smelters or refiners, supplied 3TG for parts and components supplied to us rather than to a different customer of that supplier. Accordingly, we are unable to validate that specific smelters or refiners are actually in our supply chain.

The survey we provided our suppliers included a request for mine or location of origin for the 3TG in their parts and components. When a supplier cannot directly obtain information beyond smelter or refiner name, we consult the RMAP to determine the country of origin and whether the smelter or refiner has been validated as conflict free. Below is a summary of the mineral country of origin information collected as a result of our survey process:



Andorra	France	Macedonia	Russian Federation	United Arab Emirates
Australia	Germany	Malaysia	Saudi Arabia	United Kingdom
Austria	Hong Kong	Mexico	Singapore	United States of America
Belgium	Hungary	Mozambique	South Africa	Uzbekistan
Belize	India	Myanmar	Spain	Vietnam
Bolivia	Indonesia	Netherlands	Sudan	Zambia
Brazil	Italy	New Zealand	Sweden	Zimbabwe
Canada	Japan	Norway	Switzerland
Chile	Kazakhstan	Panama	Taiwan (Province of China)
China	Korea (Republic of)	Peru	Thailand
Czech Republic	Kyrgyzstan	Philippines	Turkey
Estonia	Lithuania	Poland	Uganda

The smelters and refiners in our supply chain are based, and source their raw materials, across the globe. We believe that these smelters and refiners often mix raw materials from different countries to create the smelted or refined 3TG used in our products. Depending on the smelter or refiner’s location, the subject 3TG may be sold to commodity exchanges where smelter or refiner identity is confidential or unknown. Additionally, the total list of smelters and refiners provided by our suppliers greatly exceeded the number of known smelters and refiners and many suppliers included overlapping and duplicative information.

As discussed above, the responses provided by our direct suppliers were at the company or division level for all parts or components sent to their customers. Therefore, we cannot accurately assess whether a supplier’s listed smelters and refiners were used for the parts or components specifically supplied to us. Since, we are not able to establish a direct link between our products and particular smelters or refiners, we have not provided a delineated list of smelters and refiners.