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, 2020, 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, cassiterite, columbite-tantalite, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten.
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, 2020.
This report is not audited, as Rule 13p-1 and current SEC guidance provide that if the registrant is not declaring products as "DRC Conflict Free," the CMR is not subject to an independent private sector audit ("IPSA").
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 of our SEC filings are available on our website free of charge. Additionally, this CMR will be posted on our designated Responsible Minerals Sourcing webpage at the internet address
https://www.microchip.com/en-us/about/corporate-responsibility/responsible-minerals-sourcing.
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 and the products relating to each category for calendar year 2020 are 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"). | | | | | |
| 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"). |
| 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, midspans, 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 small quantities of tin, tantalum, tungsten and/or gold ("3TG"), necessary to their functionality or production, are found in substantially all Microchip products (Categories A, and B).
1.2 Conflict Minerals Report
For all product categories, we have been unable to conclusively determine the origin of the 3TG that our products contain, or to conclusively determine to what extent they come from recycled or scrap sources; the facilities used to process them; their country of origin; or their mine or location of origin. Our suppliers reported at broad levels, often at the company or large product family level. None of our suppliers identified which entities sourced Microchip products and none of our suppliers reported that all entities identified on their Responsible Minerals Initiative Conflict Minerals Reporting Template ("RMI-CMRT") sourced Microchip products. This report describes our Reasonable Country of Origin Inquiry (“RCOI”) for context, 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 Conflict Minerals Policy
Microchip has adopted a conflict minerals policy. Our publicly available policy is on our company website at https://www.microchip.com/en-us/about/corporate-responsibility/responsible-minerals-sourcing.
2. Microchip’s Reasonable Country of Origin Inquiry (RCOI) Results
Beginning in 2020, Microchip contracted an industry leading third-party provider help with conducting our annual RCOIs for our respective supply chains.
2.1 Category A Products
Beginning in July 2020, Microchip sent the RMI-CMRT with a set of educational and instructional documents, 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 - 2361 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 that use 100% scrap or recycled sources | Smelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered Countries |
| Tantalum | 37 of 37 | 0 of 37 | 6 of 37 | 19 of 37 |
| Tin | 53 of 53 | 0 of 53 | 9 of 53 | 3 of 53 |
| Tungsten | 38 of 38 | 0 of 38 | 2 of 38 | 5 of 38 |
| Gold | 107 of 108 | 1 of 108 | 43 of 108 | 6 of 108 |
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.
1 The total number of reported smelters represents verified legitimate smelters or refiners of 3TGs, that have been reported by at least one of your suppliers in our 2020 RCOI. Data is provided by our third-party due diligence consultants.
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2.2 Category B Products
For Category B products, Microchip started an RCOI in July 2020. 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 - 3322 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 that use 100% scrap or recycled sources | Smelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered Countries |
| Tantalum | 37 of 37 | 0 of 37 | 0 of 37 | 6 of 37 | 19 of 37 |
| Tin | 54 of 77 | 11 of 77 | 12 of 77 | 12 of 77 | 3 of 77 |
| Tungsten | 39 of 47 | 5 of 47 | 3 of 47 | 6 of 47 | 5 of 47 |
| Gold | 108 of 171 | 6 of 171 | 57 of 171 | 55 of 171 | 16 of 171 |
33 of the 43 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 ten 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.”
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 OECD Step 1: Strong Company Management Systems
Microchip operates under a set of Guiding Values and a Code of Business Conduct & Ethics that form the foundation of management systems at Microchip. Continuing through the reporting year, Microchip expressed its concern and
2 The total number of reported smelters represents verified legitimate smelters or refiners of 3TGs, that have been reported by at least one of your suppliers in our 2020 RCOI. Data is provided by our third-party due diligence consultants.
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commitment regarding conflict minerals sourcing from the DRC and Covered Countries in a publicly available policy statement on conflict minerals as outlined in Section 1.3 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 our order acknowledgments.
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, and risk management. The team is sponsored by Microchip's Sr. VP of Backend Operations, 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 was led by the Senior Manager, Compliance-Trade & Corporate Social Responsibility who acted 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 Responsible Minerals Initiative ("RMI"). Participation allows Microchip to promote validation programs (such as the RMAP or standards enacted by the London Bullion Market Association (“LBMA”) or the Responsible Jewellery Council (“RJC”)), 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 two third-party due diligence consultants experienced with smelter sourcing research and with a proven record of smelter engagement. These consultants reviewed smelter data obtained from our 2020 RCOI for Category A products and raw, and smelter data from our 2020 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
In Calendar Year 2020 Microchip engaged an industry leading third-party provider to help conduct our supplier engagement. This engagement included training and educational materials, and supplier support.
Microchip and our third-party provided reviewed responses against criteria designed to determine the number of valid responses ("Response Criteria"), and we followed up with corrections and clarifications as needed.
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. During the reporting year, we received an 100% response rate from suppliers for Category A products.
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 again encountered 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. However, hurdles still exist with our discrete component suppliers. During the reporting year, we received a 77% response rate from suppliers for Category B products. This response rate is lower than past years as the COVID-19 pandemic had a deep impact on our third-tier suppliers.
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 OECD Step 2: Identification and Assessment of 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 consultants 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 third-parties due diligence research. 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 manufacturers where mitigation appears not feasible 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 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. 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 manufacturers where mitigation appears not feasible 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. Zimbabwe's porous border and known smuggling routes will keep FPR high-risk. Unless it can become RMAP conformant. 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 manufacturers where mitigation appears not feasible 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. 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 manufacturers where mitigation appears not feasible 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. 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 manufacturers where mitigation appears not feasible 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. 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 manufacturers where mitigation appears not feasible 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. 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 manufacturers where mitigation appears not feasible or unacceptable.
Shirpur Gold Refinery Ltd. (CID002588), a gold refinery, 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. 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 manufacturers where mitigation appears not feasible or unacceptable.
3.4 OECD Step 3: Strategy to Respond to Identified 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). We use RMI recognized third-party consultants to help identify risks throughout our supply chains. We 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 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 OECD Step 4: 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 consultants 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 consultants Microchip gains insight into SORs’ sourcing practices, and their internal due diligence procedures. Microchip’s third-party due diligence consultants also encourages non-conformant/non-participating 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.
3.6 OECD Step 5: Report Annual Supply Chain Due Diligence
Microchip’s Due Diligence Review criteria includes 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. Please refer to Section 3.3 of this Conflict Minerals Report for the discussion on the steps taken on these ten findings.
As a result of our continued due diligence with suppliers and smelters through Microchip’s third-party due diligence consultant teams, Microchip has determined that approximately 99.6% of our smelters are RMAP conformant, .4% are actively pursuing their conformant status as of the end of our RCOI for our Category A products. These findings are in line with what that we saw at the end of our 2019, 2018, 2017, and 2016 RCOIs.
As a result of our continued due diligence with suppliers and smelters through Microchip’s third-party due diligence consultant teams, Microchip has determined that approximately 71.7% of our smelters are RMAP conformant, 6.6%
are actively pursuing their conformant status, and 21.7% Not currently enrolled in a validation program as of the end of our RCOI for our Category A products. This is a slight decrease from what that we saw at the end of our 2019, 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 consultants, 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 consultants, the RMI, and others, Microchip believes that the countries of origin for the 3TG in our products include the countries listed in Table 7.
While we identified 60 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.
79 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 33 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 to be Conformant with the organization’s responsible minerals sourcing protocols and are listed on the RMI RMAP “Conformant” smelter lists.
Microchip's independent due diligence produced information suggesting 43 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 to be “Conformant” with the organization’s responsible minerals sourcing protocols and are listed on the RMI RMAP “Conformant” smelter lists. For the ten
smelters reported to be in the supply chain for Category B products that were not recognized by the RMI as Conformant with the organization’s responsible minerals sourcing protocols Microchip performed additional 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: https://www.microchip.com/en-us/about/corporate-responsibility/sustainability. The information on our website is not incorporated into this CMR.
3.6.2 Efforts to Determine Mine or Location of Origin
We have determined that participation in RMI, requesting our suppliers complete the RMI CMRT, and retaining third-party due diligence consultants in the reporting year are reasonable ways to determine the mines or countries of origin of the 3TG in our supply chain. Microchip’s Countries of Origin and Reason to Believe Countries of Origin list as provided by the best of our ability based on data provided by our third-party due diligence consultants is listed in Table 7 of this CMR.
3.6.3 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, gold bond wire, and Tin Anode. All gold sputter targets, gold bond wire, 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 consultants, the facilities that may have processed the 3TG in Microchip’s Category A products include those listed in Table 1.
4. 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 third-party due diligence consultants experienced with smelter sourcing research and direct smelter engagement.
c.Conduct bi-annual reporting year RCOI for Category A products using the RMI CMRT. Microchip will communicate its expectation that suppliers for Category A 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.
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 consultants, 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
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| 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 | 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 | 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. 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 | Geib Refining Corporation | UNITED STATES OF AMERICA | |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | |
| Gold | Heimerle + Meule GmbH | GERMANY | |
| | | | | | | | | |
| Metal | Smelter Name | Smelter Country | |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | |
| Gold | Istanbul Gold Refinery | TURKEY | |
| Gold | Italpreziosi | ITALY | |
| Gold | Japan Mint | JAPAN | |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | |
| Gold | 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 | LT Metal Ltd. | 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 | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | |
| Gold | Nihon Material Co., Ltd. | JAPAN | |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | |
| | | | | | | | | |
| Metal | Smelter Name | Smelter Country | |
| Gold | OJSC Novosibirsk Refinery | 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 | SAFINA A.S. | CZECH REPUBLIC | |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | |
| Gold | Singway Technology Co., Ltd. | TAIWAN, 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 | TOO Tau-Ken-Altyn | KAZAKHSTAN | |
| Gold | Torecom | KOREA, REPUBLIC OF | |
| 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 | |
| | | | | | | | | |
| Metal | Smelter Name | Smelter Country | |
| 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 | 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 | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF | |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | |
| 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 | |
| Tantalum | Yanling Jincheng Tantalum & Niobium 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 | |
| | | | | | | | | |
| Metal | Smelter Name | Smelter Country | |
| 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 | HuiChang Hill Tin Industry Co., Ltd. | CHINA | |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | |
| Tin | Luna Smelter, Ltd. | RWANDA | |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA | |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | |
| Tin | Metallo Belgium N.V. | BELGIUM | |
| Tin | Metallo Spain S.L.U. | SPAIN | |
| Tin | Mineracao Taboca S.A. | BRAZIL | |
| Tin | Minsur | PERU | |
| Tin | Mitsubishi Materials Corporation | JAPAN | |
| Tin | 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 Babel Surya Alam Lestari | INDONESIA | |
| Tin | PT Bangka Serumpun | INDONESIA | |
| Tin | PT Menara Cipta Mulia | INDONESIA | |
| Tin | PT Mitra Stania Prima | INDONESIA | |
| Tin | PT Prima Timah Utama | INDONESIA | |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA | |
| Tin | PT Rajehan Ariq | INDONESIA | |
| Tin | PT Refined Bangka Tin | INDONESIA | |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | |
| Tin | PT Timah Tbk Kundur | INDONESIA | |
| Tin | PT Timah Tbk Mentok | INDONESIA | |
| Tin | PT Tinindo Inter Nusa | INDONESIA | |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | |
| | | | | | | | | |
| Metal | Smelter Name | Smelter Country | |
| 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 | |
| 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 | Fujian Ganmin RareMetal 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 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 | 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 | |
| | | | | | | | | |
| Metal | Smelter Name | Smelter Country | |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | |
| 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 | |
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 | Alexy Metals | UNITED STATES OF AMERICA |
| 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 | Augmont Enterprises Private Limited | INDIA |
| 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 | C.I Metales Procesados Industriales SAS | COLOMBIA |
| 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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 | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA |
| Gold | Gold Coast Refinery | GHANA |
| 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 | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| 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 | JALAN & Company | INDIA |
| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | K.A. Rasmussen | NORWAY |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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 | Kundan Care Products Ltd. | INDIA |
| 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 | LT Metal Ltd. | 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 | MD Overseas | INDIA |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA |
| 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 | 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery | 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. | CZECH REPUBLIC |
| Gold | Sai Refinery | INDIA |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | Sancus ZFS (L’Orfebre, SA) | COLOMBIA |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY |
| Gold | Sellem Industries Ltd. | MAURITANIA |
| 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 | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| Gold | Shirpur Gold Refinery Ltd. | INDIA |
| 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 |
| 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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 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 | 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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 | PRG Dooel | NORTH MACEDONIA, REPUBLIC OF |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| 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 |
| Tantalum | Yanling Jincheng Tantalum & Niobium 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 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | CRM Synergies | SPAIN |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| 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. | CHINA |
| 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | Luna Smelter, Ltd. | RWANDA |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Metallo Belgium N.V. | BELGIUM |
| Tin | Metallo Spain S.L.U. | SPAIN |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Modeltech Sdn Bhd | MALAYSIA |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | Novosibirsk Processing Plant Ltd. | RUSSIAN FEDERATION |
| 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 Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Bangka Serumpun | INDONESIA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | PT Rajehan Ariq | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Timah Nusantara | INDONESIA |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| Tin | PT Tinindo Inter Nusa | 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 | VQB Mineral and Trading Group JSC | 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 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tungsten | Artek LLC | RUSSIAN FEDERATION |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | China Molybdenum Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tungsten | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | Fujian Ganmin RareMetal 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 | GEM 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 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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 | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| 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 |
TABLE 7
Countries of Origin4
| | | | | | | | | | | |
| Argentina | Honduras | New Zealand | Tanzania |
| Australia | India | Papua New Guinea | Thailand |
| Bolivia | Indonesia | Peru | Turkey |
| Brazil | Ivory Coast | Philippines | United States of America |
| Bulgaria | Japan | Poland | Uzbekistan |
| Burkina Faso | Kazakhstan | Portugal | Vietnam |
| Burundi | Korea | Russia | Zambia |
| Canada | Kyrgyzstan | Rwanda | Zimbabwe |
| Chile | Laos | Senegal | |
| China | Mali | Sierra Leone | |
| Colombia | Mexico | South Africa | |
| Democratic Republic of the Congo | Mongolia | Sudan | |
| Georgia | Myanmar | Sweden | |
| Ghana | Namibia | Tajikistan | |
4 Microchip’s Countries of Origin and Reason to Believe Countries of Origin list as provided by the best of our ability based on data provided by our third-party due diligence consultants.
30
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 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, that participation in the Responsible Minerals Initiative allows Microchip to promote validation programs (such as the RMAP or standards enacted by the London Bullion Market Association ("LBMA") or the Responsible Jewellery Council ("RJC")), 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; and the steps set forth in Section 4 that we intend to take to improve the due diligence conducted. We also use words such as "believe," "continue," "plan," "expect," "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.
