DocumentEXHIBIT 1.01
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| CONFLICT MINERALS REPORT |
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| MICROCHIP TECHNOLOGY INCORPORATED |
| In Accord with Rule 13p-1 Under the Securities Exchange Act of 1934 |
This report for the year ended December 31, 2019, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1"). Rule 13p-1 was adopted by the United States Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank"). Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain conflict minerals necessary to the functionality or production of their products. Conflict Minerals are defined by Rule 13p-1 as gold, tin, tantalum, and tungsten (“3TG”).
If a registrant has reason to believe that any conflict minerals in their supply chain may have originated in the Democratic Republic of the Congo or an adjoining country ("Covered Countries"), or if they are unable to determine the country of origin of conflict minerals or that their products are manufactured entirely from recycled and scrap sources, then the issuer must exercise due diligence on the source and chain of custody of the conflict minerals. The registrant must annually submit a Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures. This report is Microchip Technology Incorporated's CMR for the reporting calendar year ended December 31, 2019.
For clarity, Microchip is not declaring its product as “DRC Conflict Free” as that would require this CMR to have been subjected to an independent private sector audits (“IPSA”) pursuant to Rule 13p-1 and current SEC guidance, which it has not.
1. COMPANY OVERVIEW
MICROCHIP TECHNOLOGY INCORPORATED develops, manufactures, contracts to manufacture and sells specialized semiconductor products used by its customers in a wide variety of embedded control applications. Microchip Technology Incorporated was incorporated in Delaware in 1989. In this CMR, "we," "us," and "our" each refers to Microchip Technology Incorporated and its subsidiaries ("Microchip"). Our executive offices are located at 2355 West Chandler Boulevard, Chandler, Arizona 85224-6199, and our telephone number is (480) 792-7200.
Our Internet address is www.microchip.com. This CMR will be posted on our website with our other SEC filings under About Us/Investor Relations as soon as reasonably practicable after it is electronically filed with the SEC. All our SEC filings are available on our website free of charge. Additionally, this CMR will be posted on our Conflict Minerals webpage at www.microchip.com/conflictminerals. The information on our website is not incorporated into this CMR.
1.1 Microchip Products
Microchip Technology Incorporated is a leading provider of smart, connected, and secure embedded control solutions. Its easy-to-use development tools and comprehensive product portfolio enable customers to create optimal designs, which reduce risk while lowering total system cost and time to market. The company's solutions serve more than 120,000 customers across the industrial, automotive, consumer, aerospace and defense, communications, and computing markets. Headquartered in Chandler, Arizona, Microchip offers outstanding technical support along with dependable delivery and quality. A more detailed discussion of our product categories is contained in our Annual Reports and SEC filings available on: https://www.microchip.com/documentlisting/annual-reports. For the purposes of this report, Microchip’s products are further delineated in the table below separating integrated circuits from all other types of products.
All references to “Microchip” products hereafter include Microchip and all subsidiaries’ products in Categories A and B that were manufactured by Microchip or its subsidiaries, or contracted by Microchip or its subsidiaries to be manufactured, and within the scope of Rule 13p-1 ("Microchip products") unless specifically attributed to Microchip or a specific subsidiary (e.g. "Microchip Category A products" vs. "subsidiary Category A products").
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| Conflict Minerals Disclosure Category | Conflict Minerals Product Description |
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| A | Integrated circuits including touch screen controller ICs (e.g. PIC® Microcontrollers, dsPIC® Digital Signal Controllers, touch and gesture sensing solutions, analog and interface, RF front-end products, wireless audio, USB and wireless solutions, embedded security products, memory products, medical electronics, LED drivers, printer/EL drivers, telecommunications, general industrial.) Integrated circuits including field programmable gate arrays ("FPGAs"), application-specific integrated circuits ("ASICs"), Power-over-Ethernet integrated circuits ("ICs") and midspans. |
| B | RF modules and touch screen controller boards |
| System-in-Package (SiP) hybrid modules |
| System on chip solutions ("SoCs"), Power management products; timing and synchronization devices and precise time solutions, voice processing devices; radio frequency ("RF") solutions; discrete components; enterprise storage and communication solution products, security technologies and scalable anti-tamper products; Ethernet solutions; as well as custom design capabilities and services. |
| R&D application development printed circuit boards and system kits |
We conducted an analysis of Microchip products and found that 3TG is necessary to the functionality or production of a substantial portion of Microchip products (Categories A and B).
1.2 Conflict Minerals Report
This report describes our Reasonable Country of Origin Inquiry (“RCOI”), the due diligence measures we took on the 3TG source and chain of custody, a description of the products manufactured or contracted to be manufactured for which we controlled the design and specified or approved the utilized materials, the results of our due diligence efforts, and expected risk assessment and mitigation steps.
1.3 Microchip’s Supply Chain
Microchip Products
For this reporting cycle, we completed an RCOI of all (100%) of our suppliers for Category A products. In calendar year 2019, Microchip began a new RCOI for Category B products. Microchip’s focus however was on Category A products as those are the highest volume, highest revenue products representing greater than 90% of Microchip revenue for this reporting cycle.
1.3.1 Category A – Integrated Circuits
Integrated circuits are manufactured and assembled by Microchip and contract manufacturers, and the first-tier supply chain to Microchip is best illustrated by three categories: (1) raw material suppliers; (2) silicon foundries; and (3) assembly subcontractors. Raw material suppliers support Microchip's three primary manufacturing sites where Microchip fabricates integrated circuits on raw silicon and our backend assembly sites.
1.3.2 Category B – Non-Integrated Circuits
The products that comprise Category B are more fully described above. Category B products are assembled by our contract manufacturers, Microchip's design engineers specify the type and manufacturer of each discrete component1 mounted on our Category B products not manufactured by Microchip. The contract manufacturers order the components, bare printed circuit boards, or substrates, where applicable, and materials used in these products from their lower-tier suppliers. Microchip does not have visibility or expertise to know if 3TG is necessary for functionality or production of all the materials, components, and peripheral equipment that make up the components on Category B products. The contract manufacturers may not have that visibility either. Many suppliers to the contract manufacturers, in turn, have suppliers. Transparency throughout the supply chain is challenging and takes time. We found many different methods by which Microchip's internal product design groups produced bills of materials for the contract manufacturers to use. We recognized the presence of obvious, functional 3TG - tantalum in tantalum capacitors, gold on RF impedance-constrained circuit boards and certain connectors, tin used to mount components to circuit boards, as examples. However, understanding where or if other 3TG were present, and whether they were functional, was challenging. We expect our contract manufacturers to provide information on the origin of the 3TG contained in materials chosen and purchased directly by the contract manufacturers (e.g., tin solder and bare circuit boards).
Microchip asked those same contract manufacturers to provide information on the origin of any 3TG contained in other materials, discrete components, and peripheral equipment that make up
1 Resistors, diodes, crystal oscillators, inductors, and capacitors are examples of discrete components.
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Category B products. To overcome this challenge Microchip diligently conducted outreach to its Category B supply chains. In our RCOI for Category B products (September 2019 through February 2020), we were able to achieve a response rate of 92% from our suppliers overall. Continued growth and influence of conflict minerals programs around the world and Microchip’s diligent work during our annual RCOI will yield greater supply chain transparency over time.
1.5 Conflict Minerals Policy
Microchip has adopted a conflict minerals policy. Our publicly available policy is on our company website at www.microchip.com. Our policy in effect on the date of this filing appears below in italics.
Microchip Technology Incorporated and all related subsidiaries (collectively, “Microchip”) join many others who are deeply concerned regarding the human tragedies occurring in the Democratic Republic of the Congo and adjoining countries (“Covered Countries”) associated, in part, with the mining of columbite-tantalite (tantalum), cassiterite (tin), wolframite (tungsten) and gold (“Conflict Minerals” or “3T&G”).1
These minerals originate from various continents, but armed groups engaged in, or interfering with, mining operations within the Covered Countries are believed to subject workers and indigenous people to serious human rights abuses and are using proceeds from the sale of these Conflict Minerals to finance and sustain regional conflicts. Microchip supports responsible minerals sourcing within the Covered Countries to encourage viable and ethical revenue streams for the local communities. We recognize and support the need to develop programs which allow for improved transparency in 3T&G mining and transport of Conflict Minerals and improved traceability within the 3T&G supply chain.
Microchip, its executive management and its business groups, take corporate governance and business ethics seriously. Tantalum, tin, tungsten, and gold are used in electronics products, including products manufactured by Microchip.
Microchip is diligently working toward a goal of assuring our products are manufactured and are sourced from socially responsible supply chains. In pursuit of that goal Microchip is doing the following:
•Participating as a member of the Responsible Minerals Initiative (“RMI”) that engages Smelters and Refiners (“SOR”) and conducts audits of the SOR against responsible minerals sourcing protocols. The RMI maintains lists of SOR that have successfully completed their responsible minerals sourcing audits (including audits by similar industry-specific trade organizations) or are actively participating with the RMI or similar organization (“Conformant” and “active” smelter lists, respectively), and the RMI publishes the industry-standard Conflict Minerals Reporting Template for conducting a Reasonable Country of Origin Inquiry (“RCOI”).
•Conducting a bi-annual RCOI and subsequent smelter sourcing due diligence required by the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”). Microchip uses the Responsible Minerals Initiative’s Conflict Minerals Reporting Template (“CMRT”) for our RCOI.
•Retaining professional third-party smelter sourcing due diligence.
•Presenting mineral sourcing risks to Microchip’s senior management.
•Disallowing SOR into our integrated circuit supply chain that are not cooperating with, or that are no longer cooperating with, the RMI’s Responsible Minerals Assurance Process (RMAP) or similar mineral sourcing audit programs.
•Providing information to suppliers and expecting each to source materials from socially responsible supply chains and to accurately and comprehensively disclose their list of SOR, either at company level or specific to those materials incorporated into Microchip’s products.
•Publicly disclosing our conflict minerals policy, RCOI implementation procedures, and SOR sourcing due diligence procedures.
•Microchip engages SOR where necessary, encouraging participation with the RMI’s RMAP program or their timely completion of the RMI’s third-party responsible minerals sourcing audit.
•Include a conflict minerals flow-down clause in new and renewed supplier contracts and purchase terms and conditions.
2. MICROCHIP’S REASONABLE COUNTRY OF ORIGIN INQUIRY (RCOI) RESULTS
The difference in product complexity and size of the respective supply chains of our Category A and B products necessitated different RCOI approaches for this reporting cycle.
2.1 Category A Products
Beginning in June 2019, Microchip sent the RMI CMRT with a set of educational and instructional documents, including a list of prohibited smelters, requesting the completion of the RMI CMRT to well- defined raw materials suppliers and its contract manufacturers for Category A products.
We reviewed the responses against criteria developed to determine valid responses and to identify candidates for subsequent inquiry ("Response Criteria"). For Microchip Category A inquiries, we received responses that we considered valid, including some requiring subsequent inquiry, from all first-tier suppliers.
TABLE 1
Category A Products, Smelter Metrics - 2242 Total Smelters
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| Metal | Smelters recognized by the RMI RMAP to be Conformant with their responsible minerals sourcing protocols | Smelters actively participating in sourcing audits by RMI RMAP, TI-CMC, LBMA, or similar | Smelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered Countries | Smelters that use 100% scrap or recycled sources |
| Tantalum | 37 of 37 | 0 of 37 | 18 of 37 | 5 of 37 |
| Tin | 44 of 44 | 0 of 44 | 2 of 44 | 6 of 44 |
| Tungsten | 40 of 40 | 0 of 40 | 5 of 40 | 2 of 40 |
| Gold | 103 of 103 | 0 of 103 | 7 of 103 | 38 of 103 |
All smelters for Category A products known to source from the Covered Countries, or for which there is reason to believe may source from the Covered Countries, are recognized as Conformant with RMI Responsible Minerals Assurance Process (RMAP) responsible mineral sourcing protocols and are listed on the RMI's "Conformant" smelter list.
2.2 Category B Products
For Category B products, Microchip started an RCOI in September 2019. Having identified and queried the printed circuit board manufacturers and the subcontract manufacturers’ unique materials previously, we successfully expanded our inquiry of discrete component manufacturers for all Categories and manufacturers of peripheral equipment.
TABLE 2
Category B Products, Smelter Metrics - 2973 Total Smelters
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| Metal | Smelters recognized by the RMI RMAP to be Conformant with their responsible minerals sourcing protocols | Smelters actively participating in sourcing audits by RMI RMAP, TI-CMC, LBMA, or similar | Smelters not actively participating in sourcing audits by RMI RMAP, TI- CMC, LBMA, or similar | Smelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered Countries |
| Tantalum | 38 of 39 | 1 of 39 | 0 of 39 | 19 of 39 |
| Tin | 46 of 57 | 1 of 57 | 10 of 57 | 2 of 57 |
| Tungsten | 43 of 47 | 2 of 47 | 2 of 47 | 5 of 47 |
| Gold | 106 of 154 | 1 of 154 | 47 of 154 | 15 of 154 |
33 of the 41 smelters for Category B products that are known to source from the Covered Countries, or for which there is a reason to believe may source from the Covered Countries are recognized as Conformant with RMI Responsible Minerals Assurance Process (RMAP). The remaining eight smelters that are known to source from the Covered Countries, or for which there is a reason to believe may source from the Covered Countries, are not recognized as Conformant with the RMI RMAP, thus additional due diligence was conducted. For more information on these eight smelters, please go to section 3.3.1 “Category B Identified Risks.”
65 of the 297 reported smelters for Category B products were found to be 100% scrap recyclers.
2 The total number of reported smelters represents the number of unique operational smelters reported to Microchip in 2019. Certain smelters that were found to be closed or ceased operation before 2019 are not included in this number. These smelters could not have been in or provided materials to Microchip’s supply chain.
3The total number of reported smelters represents the number of unique operational smelters reported to Microchip in 2019. Certain smelters that were found to be closed or ceased operation before 2019 are not included in this number. These smelters could not have been in or provided materials to Microchip’s supply chain
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3. MICROCHIP DUE DILIGENCE PROCESS
3.1 Design of Due Diligence
We made a good faith effort in the reporting year to work within the framework of the Organization for Economic Co-Operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing ("OECD Guidance") and related Supplements for 3TG, as it relates to our position in the supply chain as a “downstream company.”
3.2 Management Systems
Microchip operates under a set of Guiding Values and a Code of Business Conduct & Ethics that form the foundation of all management systems at Microchip. Continuing through the reporting year, Microchip expressed its concern and commitment regarding conflict minerals sourcing from the DRC and Covered Countries in a publicly available policy statement on conflict minerals as outlined in Section 1.5 above.
In addition, Microchip communicates our concern and commitment regarding conflict minerals sourcing from the DRC and Covered Countries in our Terms and Conditions of Purchase that accompanies every order acknowledgement.
3.2.1 Internal Team
Continuing through the reporting year, Microchip's management system for conflict minerals included a team of corporate representatives from relevant functions, including corporate social responsibility, legal, manufacturing, corporate environmental services, product environmental, supply management, risk management. The team is sponsored by Microchip's CFO, and senior management was briefed about the results of due diligence efforts, including minerals sourcing risks.
The conflict minerals team is responsible for implementing the conflict minerals compliance strategy, including formalizing conflict minerals due diligence practices, developing supplier risk assessment criteria and responses to risk. The team is led by the Senior Manager, Compliance-Trade & Corporate Social Responsibility who acts as the conflict minerals program manager.
3.2.2 Supply Chain Control Systems
To encourage the establishment of a system of controls and transparency over the mineral supply, we participate in the RMI. Participation allows Microchip to promote validation programs, increase our knowledge of smelters and refiners in the supply chain, understand the scope and process for audit and validation program plans for metal-specific trade organizations, gain insight into which smelters are known to source from the covered countries, and join discussions of emerging practical due diligence experiences. During the reporting year, Microchip engaged a third-party due diligence consultant experienced with smelter sourcing research and with a proven record of smelter engagement. The consultant reviewed sorted smelter data obtained from our 2019 RCOI for Category A products and raw, unsorted smelter data from our 2019 RCOI for Category B products, and then prepared a technical file for each. Mineral sourcing risk, including customer perception of sourcing risk, is presented to Microchip's senior management.
3.2.3 Microchip Supplier Engagement
Microchip’s supplier engagement activities in the reporting year again focused primarily on Category A suppliers. During the reporting year, we requested completion of the RMI CMRT by raw material suppliers and subcontract manufacturers of Category A products using an educational request letter that included training materials developed by Microchip. Microchip’s training materials consist of a prohibited smelters list, a referral to training materials produced by and available through the RMI. We reviewed responses against criteria designed to determine the number of valid responses ("Response Criteria"), and we followed up with corrections and clarifications as needed. During the reporting year, all reported smelters for Category A products were found to be listed in the RMI “Conformant” smelter lists as of December 31, 2019. Over the course of the year, the RMI de-listed several smelters; additional discussion is presented in Section 3.3, second paragraph, of this CMR.
For Microchip’s Category B products, Microchip continued and expanded its engagement with the second and third-tier discrete component and peripheral equipment
suppliers using the RMI CMRT and educational materials. We continue to encounter circumstances where the manufacturer of the discrete component declined to provide a completed CMRT because we are not their direct customer - our contract manufacturers are their direct customer. Still, the contract manufacturers are not responsible for specifying the discrete components. We have begun to work more closely with our contract manufacturers to bridge this gap.
3.2.4 Grievance Mechanism
Microchip has grievance mechanisms whereby employees, suppliers, and others can report suspected non-compliance with legal requirements and suspected non-compliance with Microchip's Code of Business Conduct & Ethics.
Our Code of Business Conduct & Ethics policy (HR-690), Compliance with Laws policy (HR-685) and Reporting Legal Non-Compliance policy (HR-675) include complaint procedures. These policies are publicly available at https://www.microchip.com/about-us/corporate-responsibility/ethics-conduct
For additional conflict minerals related grievance, Microchip employees and external parties may also submit concerns or information to ConflictMinerals@Microchip.com
3.2.5 Maintain Records
Microchip has developed a process for collecting and retaining RCOI and due diligence documentation that was directed, controlled, and archived by the conflict minerals team.
3.3 Identify and Assess Risk in the Supply Chain
Because of our size, the complexity of our products, and the depth, breadth, and evolution of our supply chain, it can be challenging to identify suppliers upstream from our first tier (direct) suppliers. Accordingly, we identify direct suppliers that supply products to us that may contain conflict minerals. We pursue smelter identification using the RMI CMRT; additionally, Microchip leverages our membership in the RMI as an integral part of our supply chain identification and due diligence and risk
assessment processes. Additionally, Microchip uses our third-party due diligence consultant to gain insight into SORs’ sourcing practices, and their internal due diligence procedures to help with risk assessment.
3.3.1 Category B Identified Risks
African Gold Refinery (CID003185), a gold refinery, was reported in our Category B products’ supply chain. This smelter, which is located within the Great Lakes Region of the Covered Countries, presents a credible risk of irresponsible sourcing based upon our due diligence research. As such, Microchip promptly engaged its Category B supply chain to remove this smelter. Many suppliers voluntarily removed African Gold Refinery from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 46% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.
Sudan Gold Refining (CID002567), a state-owned gold refinery, was reported in our Category B products’ supply chain. This smelter may present a risk of irresponsible sourcing within the Covered Countries. As such Microchip promptly engaged its Category B supply chain to remove this smelter. Many suppliers voluntarily removed Sudan Gold Refining from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 45% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.
Kaloti Precious Metals (CID002563), a gold smelter, was reported in our Category B products’ supply chain. It has come to our attention during our third-party due diligence review that there is a reason to believe that this smelter may present a risk of irresponsible sourcing within the Covered Countries as this smelter is located in a country without a domestic source of gold. Additionally, Kaloti Precious Metals is not listed on the RMI-RMAP Conformant List for Gold
thus has not been audited by any entity accepted by the RMI audit protocols. As such, Microchip promptly engaged its was reported in our Category B supply chain to remove this smelter. Many suppliers voluntarily removed Kaloti Precious Metals from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 50% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.
Fidelity Printers and Refiners Ltd. (CID002515), a gold refinery, was reported in our Category B products’ supply chain. This smelter may present a risk of irresponsible sourcing within the Covered Countries. As such Microchip promptly engaged its Category F supply chain to remove this smelter. Many suppliers voluntarily removed Fidelity Printers and Refiners Ltd. from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 47% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain, and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.
Tony Goetz NV (CID002587), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. As such Microchip promptly engaged its Category B supply chain to remove this smelter. Many suppliers voluntarily removed Tony Goetz NV from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 47% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.
Dijllah Gold Refinery FZC (CID003348), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. Many suppliers voluntarily removed Dijllah Gold Refinery FZC from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 42% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.
Fujairah Gold (CID002584), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. Many suppliers voluntarily removed Fujairah Gold from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 42% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.
International Precious Metal Refiners (CID002562), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. Many suppliers voluntarily removed International Precious Metal Refiners from their supply chain and provided validation in the form of a revised CMRT. Through this engagement process Microchip was able to achieve a 43% removal rate for this smelter. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturer where mitigation appears infeasible or unacceptable.
3.4 Design and Implement a Strategy to Respond to Risks
We believe that understanding smelter sourcing practices is the best method that can eventually lead to the determination of a product's conflict status. To that end, Microchip is a member of the RMI. We review the lists of smelters reported by our supply chain against the RMI RMAP "Conformant" smelter lists, their "active" smelter lists, the TI-CMC "active" smelter list (TI-CMC Category A, Members Progressing Toward RMAP Validation), and the KUMA “active” smelter list (KUMA, Members Progressing Toward RMAP Validation). We plan to engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that support conflict in the Covered Countries to seek to establish an acceptable alternative source of 3TG that does not support such conflict. We also engage directly with smelters reported by our supply chain and for which we can locate viable contact information to voluntarily participate in the RMI RMAP or similar sourcing audit programs leading to recognition by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols.
3.5 Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not typically have a direct relationship with 3TG smelters and refiners, and do not perform direct audits of these entities within our supply chain. Microchip does, however, leverage our third-party due diligence consultant to contact smelters and refiners that we do not have direct relationships with or do not have the ability to contact. Using our third-party due diligence consultant, Microchip gains insight into SORs’ sourcing practices, and their internal due diligence procedures. Microchip’s third-party due diligence consultant also encourages non-conformant SORs to become conformant by joining the RMI or affiliated groups on our behalf. Additionally, Microchip utilizes and supports the due diligence conducted by programs like the RMI to conduct and coordinate third-party audits to validate 3TG processors sourcing practices.
During the reporting year, Microchip purchased gold sputter targets from one large refiner, and Tin Anode from one large refiner, each of which is recognized by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols. We support responsible minerals sourcing audits through membership with the RMI.
3.6 Report on Supply Chain Due Diligence
In addition to this CMR, we communicate our conflict minerals activities in our annual Sustainability Report and in our conflict minerals sourcing policy, which are available on our company website: www.microchip.com. The information on our website is not incorporated into this CMR.
4. DUE DILIGENCE RESULTS
4.1 Request Information
We conducted a Reasonable Country of Origin Inquiry (“RCOI”) of those suppliers described above using the RMI CMRT. The RMI CMRT was developed to facilitate disclosure and communication of information regarding smelters and refiners that provide 3TG to a company's supply chain.
4.2 Summary Results for All Product Categories
As a result of our continuous due diligence with suppliers and smelters through Microchip’s third-party due diligence consultant team, Microchip has determined that approximately 100% of our smelters are RMAP conformant as of the end of our RCOI for our Category A products. These are the same results that we saw at the end of our previous three reporting cycles.
Microchip determined that approximately 78% of our smelters reported in our Category B products are RMAP conformant as of the end of our RCOI. For our Category B products, this is a slight decrease from the results that we saw at the end of 2018 and 2017.
Based on RCOI information provided by suppliers in Microchip's supply chains, our due diligence efforts, and due diligence provided by our third-party due diligence consultant, the SORs that may have processed the 3TG in Microchip's Category A products include those listed in Table 1. The SORs that may have processed the 3TG in Category B products include those listed in Table 2.
Based on our due diligence efforts, Microchip does not have sufficient information to conclusively determine the countries of origin for the 3TG in our products. Based on the information provided by Microchip's suppliers, our third-party due diligence consultant, the RMI, and others, Microchip believes that the countries of origin for the 3TG in our products include the countries listed in Table 5.
While we identified 51 smelters for Category A products that use exclusively scrap or recycled sources of 3TG, we determined that no correlation can be made to any specific Microchip Category A product type, technology family, or part number. No Microchip Category A product is made exclusively with 3TG solely sourced from scrap or recycled sources.
65 smelters in our Category B products were found to source from scrap or recycled sources of 3TG exclusively, however, we determined that no correlation can be made to any specific Microchip Category B product types, technology families, or part number. No Category B product is made exclusively with 3TG solely sourced from scrap or recycled sources.
Microchip's independent due diligence produced information suggesting 32 reported smelters for Category A products either are known to source from the Covered Countries, or there is reason to believe may or could source from the Covered Countries based upon business relationships. Each of these smelters is recognized by the RMI RMAP to be Conformant with the organization’s responsible minerals sourcing protocols and is listed on the RMI RMAP “Conformant” smelter lists.
Microchip's independent due diligence produced information suggesting 41 reported smelters for Category B products either are known to source from the Covered Countries or there is reason to believe may source from the Covered Countries. 33 of these smelters are recognized by the RMI RMAP to be “Conformant” with the organization’s responsible minerals sourcing protocols and are listed on the RMI RMAP “Conformant” smelter lists. For the eight smelters reported to be in the supply chain for Category B products that were neither recognized by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols and listed on the RMI RMAP “Conformant” smelter lists nor the organization’s "active" smelter lists, or the TI-CMC "active" smelter list (TI-CMC Category A Members Progressing Toward RMAP Validation), Microchip performed additional due diligence. The review criteria include a determination of the geographic location, whether there is a known, actively mined, and economically viable reserve of 3TG in the area, whether there is positive evidence of responsible and/or irresponsible sourcing, whether there is contrary evidence of responsible sourcing - all from publicly available sources, the smelters’ websites, the UN Group of Experts, NGOs, the RMI and similar organizations, and from our due diligence consultant’s communication with certain smelters. From this due diligence review for all product categories Microchip concludes:
•There were 8 findings during our due diligence of possible irresponsible mineral sourcing. Please refer to Section 3.3 of this Conflict Minerals Report for the discussion on the steps taken on these eight findings. For the remaining 33 smelters, there was no evidence of irresponsible sourcing.
4.3 Efforts to Determine Mine or Location of Origin
We have determined that participation in RMI, requesting our suppliers complete the RMI CMRT, and retaining a third-party due diligence consultant in the reporting year are reasonable ways to determine the mines or countries of origin of the 3TG in our supply chain.
4.4 Smelters or Refiners
Microchip does not source 3TG directly from the Covered Countries, and Microchip typically does not source 3TG directly from smelters or refiners. The exceptions are gold sputter targets, and Tin Anode. All gold sputter targets, and Tin Anode, were purchased from smelters or refiners recognized by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols.
Based on RCOI information provided by suppliers in Microchip’s supply chains, our own due diligence efforts, and due diligence provided by our consultant, the facilities that may have processed the 3TG in Microchip’s Category A products include those listed in Table 1.
4.4.1 Category B
Microchip does not source 3TG directly from the Covered Countries, and Microchip does not source 3TG directly from smelters or refiners for Category B products. The facilities that may have processed the 3TG in Category B products include those listed in Table 2.
5. STEPS TO BE TAKEN TO MITIGATE RISK
We intend to take the following steps to improve the due diligence conducted to further mitigate risk that the necessary conflict minerals in our products could benefit armed groups in the Covered Countries:
a.Continue to work with the RMI and/or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance and/or other SEC recognized framework.
b.Consolidate RCOI and due diligence practices and activities into a conflict minerals management system. Continue to retain a third-party due diligence consultant experienced with smelter sourcing research and direct smelter engagement.
c.Conduct annual reporting year RCOI for Category A products using the RMI CMRT.
d.Conduct annual reporting year RCOI for Category B products using RMI CMRT. Microchip will communicate its expectation that suppliers for Category B products working to remove uncooperative smelters, and smelters that are not actively participating with the RMI RMAP, or similar sourcing programs from the products they provide to Microchip through Microchip's contract manufacturers.
e.Continue to develop supplier engagement strategies that may improve the RCOI response rate for Category B suppliers where Microchip is a second-tier customer or lower.
f.Through our efforts or those of our due diligence consultant, engage with selected smelters to encourage participation with the RMI RMAP responsible minerals sourcing audits.
g.Continue to remove smelters from our Category A supply chain that become uncooperative with the RMI RMAP, or who were at one time, voluntarily participating with the RMI RMAP responsible minerals sourcing audit program or similar programs but who have fallen off the “Conformant” smelter lists unless the RMI places the smelter into its “smelters undergoing extended corrective action” category. Microchip will review the business need for a smelter in this category and may, depending on the cause for removal and the nature and content of affirmative commitments made by the affected smelter, choose to retain the smelter in its supply chain.
h.Engage with direct suppliers found to be supplying us with 3TG from sources that support conflict in any Covered Country to seek to establish an acceptable alternative source of 3TG.
TABLE 5
Category A Products
Smelters Reported to be in Supply Chain
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | 8853 S.p.A. | ITALY |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | Asahi Refining Canada Ltd. | CANADA |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangalore Refinery | INDIA |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY |
| Gold | Dowa | JAPAN |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA |
| Gold | 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 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | PAMP S.A. | SWITZERLAND |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | REMONDIS PMR B.V. | NETHERLANDS |
| Gold | Royal Canadian Mint | CANADA |
| Gold | SAAMP | FRANCE |
| 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | 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 | Torecom | KOREA, REPUBLIC OF |
| 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 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 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| 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 | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | Dowa | JAPAN |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Gejiu Non-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 Hanhe Non-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 | Jiangxi New Nanshan Technology 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 | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIETNAM |
| Tin | Thaisarco | THAILAND |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Yunnan Tin Company Limited | CHINA |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
| 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 Jiangwu Ferrotungsten 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 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| 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 Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIETNAM |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| 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 |
TABLE 6
Category B Products
Smelters Reported to be in Supply Chain
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | 8853 S.p.A. | ITALY |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | African Gold Refinery | UGANDA |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL |
| Gold | Argor-Heraeus S.A. | SWITZERLAND |
| Gold | Asahi Pretec Corp. | JAPAN |
| Gold | 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 |
| 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 | CGR Metalloys Pvt Ltd. | INDIA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY |
| Gold | Dowa | JAPAN |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. North Plant | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant | JAPAN |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| 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 | Guangdong Jinding Gold Limited | CHINA |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | 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 | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| 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 Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| 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 | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Gold Co., Ltd. | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | Marsam Metals | BRAZIL |
| Gold | Materion | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA |
| Gold | Metalor Technologies S.A. | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Modeltech Sdn Bhd | MALAYSIA |
| Gold | Morris and Watson | NEW ZEALAND |
| 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 | NH Recytech Company | KOREA, REPUBLIC OF |
| 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 Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | PAMP S.A. | SWITZERLAND |
| Gold | Pease & Curren | UNITED STATES OF AMERICA |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
| 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 | SAFINA A.S. | CZECHIA |
| Gold | Sai Refinery | INDIA |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sovereign Metals | INDIA |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | Sudan Gold Refinery | SUDAN |
| 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 | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | Tony Goetz NV | BELGIUM |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| 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 | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | CP Metals Inc. | UNITED STATES OF AMERICA |
| 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 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 JinXin Nonferrous Metals Co., Ltd. | CHINA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| 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 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tin | Dowa | JAPAN |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Estanho de Rondonia S.A. | BRAZIL |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd.” | |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Gejiu Non-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 Hanhe Non-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 | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Pongpipat Company Limited | MYANMAR |
| Tin | Precious Minerals and Smelting Limited | INDIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Super Ligas | BRAZIL |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIETNAM |
| Tin | Thaisarco | THAILAND |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Yunnan Tin Company Limited | CHINA |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tungsten | Fujian Ganmin RareMetal 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 Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Hunan Litian Tungsten Industry 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 Dayu Longxintai Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIETNAM |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF |
| 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 |
TABLE 9
Countries of Origin4
| | | | | | | | | | | |
| Andorra | Germany | Mexico | Sweden |
| Argentina | Ghana | Myanmar | Switzerland |
| Australia | Guinea | Netherlands | Taiwan, Province Of China |
| Austria | India | New Zealand | Tajikistan |
| Belgium | Indonesia | Papua New Guinea | Tanzania |
| Bolivia (Plurinational State Of) | Italy | Peru | Thailand |
| Brazil | Japan | Philippines | Turkey |
| Burundi | Kazakhstan | Poland | Uganda5 |
| Canada | Korea, Republic Of | Russian Federation | United Arab Emirates6 |
| Chile | Rwanda | United States Of America | China |
| Kyrgyzstan | Saudi Arabia | Uzbekistan | Czechia |
| Lithuania | Singapore | Vietnam | Democratic Republic Of The Congo |
| Macedonia, The Former Yugoslav Republic Of | South Africa | Zambia | Estonia |
| Malaysia | Spain | Zimbabwe7 | France |
| Mali | Sudan8 | | |
4 Microchip’s Countries of Origin and Reason to Believe Countries of Origin list as provided by the best of our ability.
5 Please refer to Section 3.3, of this Conflict Minerals Report for the discussion of due diligence and removal action taken against African Gold Refinery, the only reported smelter in Uganda.
6 Please refer to Section 3.3, of this Conflict Minerals Report for the discussion of due diligence and removal action taken against Dijllah Gold Refinery FZC, Fujairah Gold, and International Precious Metal Refiners.
7 Please refer to Section 3.3, of this Conflict Minerals Report for the discussion of due diligence and removal action taken against Universal Precious Metals Refining Zimbabwe, the only reported smelter in Zimbabwe.
8 Please refer to Section 3.3, of this Conflict Minerals Report for the discussion of due diligence and removal action taken against Sudan Gold Refinery, the only reported smelter in Sudan.
32
Caution Concerning Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Such forward-looking statements include the statements that continued growth and influence of conflict minerals programs around the world and Microchip's diligent work during our annual RCOI will yield greater supply chain transparency over time, we are working toward a goal to ensure our products are manufactured and/or sourced from socially responsible supply chains, that we plan to engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that support conflict in the DRC and the steps set forth in Section 5 that we intend to take to improve the due diligence conducted. We also use words such as "anticipate," "believe," "plan," "expect," "future," "intend" and similar expressions to identify forward-looking statements. All forward-looking statements involve risk and uncertainty. Our actual results could differ materially from the results anticipated in these forward-looking statements for a number of reasons including changes in our supply chain, our ability or inability to obtain an adequate supply of materials from current or alternative suppliers and the cost of such materials, the level of cooperation we receive from our suppliers with respect to our further due diligence, changes in regulations in the U.S. or other countries (including the Covered Countries), or changes in political or economic conditions in the U.S. or other countries (including the Covered Countries). For a detailed discussion of these and other risk factors, please refer to Microchip's filings on forms 10-K and 10-Q. You can obtain copies of Forms 10-K and 10-Q and other relevant documents for free at Microchip's website (www.microchip.com) or the SEC's website (www.sec.gov) or from commercial document retrieval services. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. Although we believe that the expectations reflected in the forward-looking statements are reasonable, we cannot guarantee future results, levels of activity, performance, or achievements. You should not place undue reliance on these forward-looking statements. We disclaim any obligation to update information contained in any forward-looking statement.
