UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
QuickLogic Corporation
(Exact name of registrant as specified in its charter)
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Delaware |
000-22671 |
77-0188504 |
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(State or other jurisdiction of incorporation) |
(Commission File Number) |
(IRS Employer Identification No.) |
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2220 Lundy Avenue, San Jose, CA |
95131-1816 |
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(Address of principal executive offices) |
(Zip Code) |
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Elias Nader
Chief Financial Officer and Senior Vice-President, Finance
(408) 990-4000
(Name and telephone number, including area code, of the person to contact in connection with this report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
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☒ |
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2023 to December 31, 2023. |
| ☐ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended _______. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
QuickLogic Corporation ("QuickLogic", "we" or the "Company") is filing this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 for the reporting period from January 1, 2023 to December 31, 2023 (the "Reporting Period").
Rule 13p-1, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain "conflict minerals" (as defined below) are necessary to the functionality or production of such products. Form SD defines "conflict minerals" as: (i)(a) columbite-tantalite (or coltan, the metal ore from which tantalum is extracted), (b) cassiterite (the metal ore from which tin is extracted), (c) gold, and (d) wolframite (the metal ore from which tungsten is extracted), or their derivatives, which are currently limited to tantalum, tin, and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an "adjoining country," as such term is defined in Form SD (collectively, the "Covered Countries").
The Company's operations may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products (collectively, the "Covered Products"). As required by Form SD, the Company has conducted a good faith reasonable country of origin inquiry ("RCOI") regarding the conflict minerals included in its Covered Products during the Reporting Period to determine whether any such Conflict Minerals originated in the Covered Countries and/or whether any of the Conflict Minerals were from recycled or scrap sources. Where applicable, the Company has conducted additional due diligence regarding the sources of the Conflict Minerals. The results of the Company's RCOI regarding the Conflict Minerals, as well as its additional due diligence regarding the sources of such Conflict Minerals, are contained in the Company's Conflict Minerals Report, a copy of which is filed as Exhibit 1.01 to this Form SD, and is publicly available at http://ir.quicklogic.com. The reference to the Company's website is provided for convenience only, and its contents are not incorporated by reference into this Form SD, nor are they deemed "filed" with the U.S. Securities and Exchange Commission pursuant to the Exchange Act or the Securities Act of 1933, as amended.
Item 1.02 Exhibit.
The Company's Conflict Minerals Report is included as Exhibit 1.01 to this Form SD.
Section 2 – Resource Extraction Issuer Disclosure
Not applicable.
Section 3 - Exhibits
Item 3.01 Exhibits.
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Conflict Minerals Report for the reporting period of January 1, 2023 to December 31, 2023. |
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
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Date: June 21, 2024 |
QuickLogic Corporation |
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/s/ Elias Nader |
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| Elias Nader | ||
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Chief Financial Officer, and Senior Vice-President, Finance |
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Exhibit 1.01
QuickLogic Corporation
Conflict Minerals Report
For The Reporting Period from January 1, 2023 to December 31, 2023
Introduction
This Conflict Minerals Report (the “Report”) of QuickLogic Corporation (“QuickLogic”, “we”, “our”, or the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023 (the "Reporting Period").
Rule 13p-1, through Form SD, requires the disclosure of certain information if a company manufactures or contracts to manufacture products for which certain "conflict minerals" (as defined below) are necessary to the functionality or production of such products. Form SD defines "conflict minerals" as: (i)(a) columbite-tantalite (or coltan, the metal ore from which tantalum is extracted), (b) cassiterite (the metal ore from which tin is extracted), (c) gold, and (d) wolframite (the metal ore from which tungsten is extracted), or their derivatives, which are currently limited to tantalum, tin, and tungsten; or (ii) any other mineral or its derivatives determined by the U.S. Secretary of State to be financing conflict in the Democratic Republic of the Congo or an "adjoining country," as such term is defined in Form SD (collectively, the "Covered Countries"). The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of Congo (the “DRC”), the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Our operations may at times manufacture, or contract to manufacture, products for which conflict minerals are necessary to the functionality or production of those products (collectively, the "Covered Products"). As required by Form SD, we have conducted a good faith reasonable country of origin inquiry ("RCOI") regarding the conflict minerals included in its Covered Products during the Reporting Period to determine whether any such Conflict Minerals originated in the Covered Countries and/or whether any of the Conflict Minerals were from recycled or scrap sources. Where applicable, we have conducted additional due diligence regarding the sources of the Conflict Minerals. The results of our RCOI regarding the Conflict Minerals, as well as our additional due diligence regarding the sources of such Conflict Minerals, are contained in this Report, which is publicly available at http://ir.quicklogic.com. The reference to the Company's website is provided for convenience only, and its contents are not incorporated by reference into this Form SD, nor are they deemed "filed" with the U.S. Securities and Exchange Commission pursuant to the Exchange Act or the Securities Act of 1933, as amended.
Overview
QuickLogic Corporation is a fabless semiconductor provider of comprehensive, flexible sensor processing solutions, ultra-low power display bridges, and ultra-low power Field Programmable Gate Arrays. The Company enables Original Equipment Manufacturers ("OEMs") to maximize battery life for highly differentiated, immersive user experiences with Smartphone, Wearable, Hearable, Tablet, and Internet-of-Things or IoT hardware products, and Military, Aerospace, and Defense products. QuickLogic delivers these benefits through industry leading ultra-low power customer programmable System on Chip semiconductor solutions, embedded software, and algorithm solutions for always-on voice and sensor processing. The Company’s wholly owned subsidiary, SensiML Corp. ("SensiML"), provides Analytics Toolkit, which is used in many of the applications where the Company’s ArcticPro™, eFPGA intellectual property plays a critical role. SensiML Analytics toolkit is an end-to-end software suite that provides OEMs a straightforward process for developing pattern matching sensor algorithms using machine learning technology that are optimized for ultra-low power consumption.
The Company conducted an analysis of the products that it contracted to be manufactured during the Reporting Period and reasonably determined certain Conflict Minerals, primarily gold, tantalum, tin, and tungsten, are necessary to the functionality or production of the majority of its products.
Description of the Company’s Reasonable Country of Origin Inquiry
As described in this Report, we have determined that the following Conflict Minerals, namely gold, tantalum, tin and tungsten, are necessary to the functionality or production of products contracted to be manufactured by us during the Reporting Period. As a result, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) reasonably designed to determine if any of these Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources, in accordance with Form SD and related guidance provided by the Securities and Exchange Commission ("SEC"). Our supply chain is complex and there are many third parties in the supply chain between the ultimate manufacturer of the Covered Products and the original sources of Conflict Minerals. The Company does not directly purchase Conflict Minerals from mines, smelters or refiners. Therefore, the Company must rely on suppliers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products. In designing our RCOI, we employed a combination of measures to determine whether the Conflict Minerals in our Covered Products originated from the Covered Countries and determined that the Company would survey each of its Tier 1 suppliers.
As such, our RCOI primarily consisted of utilizing the Conflict Minerals Reporting Template (“CMRT”) prepared by the Responsible Minerals Initiative ("RMI"), an initiative of the Responsible Business Alliance and Global e-Sustainability Initiative for Tier 1 suppliers of our devices in 2023. Only CMRT’s 6.31 or higher were accepted. Responses were reviewed for completeness, reasonableness and consistency, and we routinely followed up for any corrections and clarifications. During 2023, we contracted with Source 44 LLC dba Source Intelligence, a third-party vendor to coordinate the efforts of receiving and analyzing the CMRTs. Through Source Intelligence’s database, we received detailed information regarding the smelters/refiners and associated mine countries reported in our supply chain.
We submitted this template to four (4) Tier 1 suppliers and received a 100% response rate. Of these responding suppliers, 100% indicated one or more of the Conflict Minerals are necessary to the functionality or production of the products supplied.
Description of the Company’s Due Diligence Process
Based on this information, we performed additional due diligence on the source and chain of custody of these Conflict Minerals. The Company's due diligence measures have been designed to conform to the framework in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the "OECD Guidance"). The OECD Guidance is an internationally recognized due diligence framework.
In accordance with the five-step OECD Guidance, the design of our due diligence includes, but is not limited to, the following five steps: (i) establishment of strong company management systems, (ii) identification and assessment of risks in the supply chain, (iii) designing and implementing a strategy to respond to identified risks, (iv) carrying out an independent third-party audit of smelter/refiner’s due diligence practices and (v) reporting on supply chain due diligence. A description of certain activities undertaken by us in respect of each of the five steps of the OECD Guidance is described below.
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1. |
Establishment of Strong Company Management Systems |
We have completed a number of steps to establish a management system for addressing the sourcing of Conflict Minerals in our Covered Products. These actions include:
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a. |
Adopt and Commit to a Supply Chain Policy for Conflict Minerals: Our Conflict Minerals Policy is available at https://www.quicklogic.com/support/conflict-minerals-policy/. Our Policy underscores the Company’s commitment to ethical business conduct and the responsible sourcing of minerals and to working with our suppliers to ensure compliance with SEC regulations. |
Our Policy notes the Company’s support of the industry-wide efforts the Responsible Business Alliance and Global e-Sustainability Initiative are making to address responsible sourcing of minerals through the development of the Responsible Minerals Initiative. Our policy discusses the Company’s adoption and use of the industry-standard CMRT created by the Responsible Business Alliance and Global e-Sustainability Initiative to collect sourcing information related to conflict minerals as an element of our reasonable country of origin inquiry to verify the responsible sourcing of materials and to support compliance with SEC regulations. Listed below under the Findings are the results of the sourcing of minerals provided by the Tier 1 suppliers.
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b. |
Internal Management to Support Supply Chain Due Diligence: Our Vice President of Operations participates in the design and execution of our conflict minerals program and cooperates to manage and support our supply chain due diligence. The VP of Operations identified the suppliers to be contacted and adopted and approved for use the Reporting Template discussed above. The VP of Operations interacts directly with our suppliers and third party, Source Intelligence, to obtain updated and current Reporting Templates and analyzes the information provided on the sourcing of the conflict minerals used in the manufacture of the Covered Products. Each response is reviewed to identify missing information and unclear responses. The VP of Operations meets regularly with Source Intelligence to discuss the results of the due diligence efforts and appropriate follow-up measures to be taken with our suppliers. The Vice President of Operations reports on the status of the Company’s supply chain due diligence at regularly scheduled meetings of the Company’s Board of Directors. |
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c. |
Controls and Transparency to Support Supply Chain Diligence: We use the CMRT to identify the smelters and refiners that are in the supply chain of each of our suppliers. We review and compare this list to the list of smelters and refiners identified by the Responsible Minerals Initiative to be eligible, active, or conformant in its Responsible Minerals Assurance Process ("RMAP"). This enables us to identify the smelters and refiners that have been determined to be in conformance with the applicable RMI standards and those that are currently undergoing assessment or are eligible for assessment as a part of the RMI's RMAP. We use Source Intelligence's database to further verify the smelter/refiners sourcing information. We have determined that this approach represents the most reasonable effort we can make to determine whether the minerals used in the production of our Covered Products are conflict-free. |
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d. |
Supplier Engagement: We are dependent upon our suppliers to manufacture the Covered Products. We continue to work with our suppliers to support their efforts to identify the sources and status of the Conflict Minerals used in our Covered Products and to encourage each smelter and refiner in our supply chain to undergo RMAP assessment or continue previously established conformance with RMI standards. We continue to actively engage with our suppliers to strengthen our relationship with them and we have communicated to them our commitment to sourcing Conflict Minerals in a manner that does not benefit armed groups in the Covered Countries. |
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e. |
Grievance Mechanism: We have grievance mechanisms in place that enable employees and suppliers to report violations of the Company’s policies. We have a compliance hotline which is operated by an independent company that may be called at any time to report grievances and invite individuals with grievances to bring these matters to the attention of the Audit Committee of our Board of Directors by written correspondence on a confidential basis. We also employ an email address by which matters may be brought at any time to the attention of the VP of Operations by sending an email to conflictminerals@quicklogic.com. |
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2. |
Identification and Assessment of Risks in the Supply Chain |
Because of our position within our supply chain, it is difficult to identify actors upstream from our Tier 1 suppliers. As discussed above, we identified Tier 1 suppliers and we have relied upon them to provide us with the necessary information about the source of Conflict Minerals contained in the products they manufacture on our behalf. Our suppliers are similarly reliant upon information provided by their suppliers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products.
We request each of them to complete the CMRT and review the sourcing information provided in response to our requests for accuracy and completeness. In the event we find the responses to the Reporting Template unclear or incomplete, we contact the supplier in question for additional information and clarification. In some cases, we may contact the smelter or refiner directly to obtain information. We intend to contact each of our suppliers at least once per year to check on the status of their continuing due diligence and to obtain updated information. We record all information obtained from the CMRT to identify the smelters and refiners in our supply chain. The list of the smelters and refiners in our supply chain are verified against the lists compiled by the Responsible Minerals Initiative, TI-CMC, LBMA and RJC to determine which smelters and refiners have been determined to be compliant with the Responsible Minerals Assurance Process assessment protocols and certifications.
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3. |
Designing and Implementing a Strategy to Respond to Identified Risks |
In response to this risk assessment, the Company has an approved risk management plan which is implemented, managed, and monitored by the Vice President of Operations under the oversight of our Board of Directors. Any identified potential risks or quality control flags raised during the evaluation of supplier responses are noted on the Source Intelligence platform and reviewed by the team. We support the continued efforts of the Responsible Minerals Initiative to complete the audits of smelters that have agreed to date to participate in the Responsible Minerals Assurance Process and to encourage other identified smelters to become participants.
As a continuing part of our risk management plan, we have communicated our commitment to the use of conflict-free minerals in the manufacture of our Covered Products and our expectation that the manufacture of our Covered Products will be conflict-free.
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4. |
Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
We do not have a direct business relationship with any smelters or refiners in our supply chain and, as a result, we do not directly conduct or request audits. Instead, we support the development and implementation of independent third-party audits of smelters by encouraging our suppliers to purchase materials from smelters in conformance with RMI standards and determine whether the smelters that were used to process these minerals were validated as in conformance with RMI standards as part of the Responsible Minerals Assurance Process. We monitor smelters' or refiners' conformance status with Source Intelligence and the Responsible Minerals Initiative.
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5. |
Reporting on Supply Chain Due Diligence |
In 2024, we publicly filed the Form SD and this Report with the SEC, and a copy of this Report and the Form SD are publicly available at http://ir.quicklogic.com.
This Report includes information about the RCOI methodology utilized by the Company, the design of our due diligence process in conformance with the OECD Guidelines, and the list of known smelters utilized in our supply chain identified in our due diligence process.
Findings
Based on the information that was provided by the Company’s Tier 1 suppliers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products include the smelters and refiners listed below. As of June 14, 2024, 217 of the 219 smelters below were in conformance with the standards as established by the Responsible Minerals Initiative’s RMAP. The remaining two smelters are currently undergoing the RMAP assessment. There is an indication of DRC-sourcing for 33 smelters/refiners used.
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Smelter Name |
Smelter ID |
Smelter Country |
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Gold |
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Abington Reldan Metals, LLC |
CID002708 |
United States |
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Advanced Chemical Company |
CID000015 |
United States |
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Agosi AG |
CID000035 |
Germany |
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Aida Chemical Industries Co., Ltd. |
CID000019 |
Japan |
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Almalyk Mining and Metallurgical Complex (AMMC) |
CID000041 |
Uzbekistan |
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AngloGold Ashanti Corrego do Sitio Mineracao |
CID000058 |
Brazil |
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Argor-Heraeus S.A. |
CID000077 |
Switzerland |
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Asahi Pretec Corp. |
CID000082 |
Japan |
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Asahi Refining Canada Ltd. |
CID000924 |
Canada |
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Asahi Refining USA Inc. |
CID000920 |
United States |
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Asaka Riken Co., Ltd. |
CID000090 |
Japan |
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Aurubis AG |
CID000113 |
Germany |
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Bangalore Refinery |
CID002863 |
India |
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
CID000128 |
Philippines |
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Boliden AB |
CID000157 |
Sweden |
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C. Hafner GmbH + Co. KG |
CID000176 |
Germany |
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CCR Refinery - Glencore Canada Corporation |
CID000185 |
Canada |
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Chimet S.p.A. |
CID000233 |
Italy |
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Chugai Mining |
CID000264 |
Japan |
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Dowa |
CID000401 |
Japan |
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DSC (Do Sung Corporation) |
CID000359 |
Korea, Republic of |
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Eco-System Recycling Co., Ltd. East Plant |
CID000425 |
Japan |
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Eco-System Recycling Co., Ltd. North Plant |
CID003424 |
Japan |
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Eco-System Recycling Co., Ltd. West Plant |
CID003425 |
Japan |
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Gold by Gold Colombia |
CID003641 |
Colombia |
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Gold Refinery of Zijin Mining Group Co., Ltd. |
CID002243 |
China |
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Heimerle + Meule GmbH |
CID000694 |
Germany |
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Heraeus Germany GmbH Co. KG |
CID000711 |
Germany |
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Heraeus Metals Hong Kong Ltd. |
CID000707 |
China |
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Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
CID000801 |
China |
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Ishifuku Metal Industry Co., Ltd. |
CID000807 |
Japan |
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Istanbul Gold Refinery |
CID000814 |
Turkey |
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Italpreziosi |
CID002765 |
Italy |
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Japan Mint |
CID000823 |
Japan |
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Jiangxi Copper Co., Ltd. |
CID000855 |
China |
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JX Nippon Mining & Metals Co., Ltd. |
CID000937 |
Japan |
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Kazzinc |
CID000957 |
Kazakhstan |
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Kennecott Utah Copper LLC |
CID000969 |
United States |
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KGHM Polska Miedz Spolka Akcyjna |
CID002511 |
Poland |
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Kojima Chemicals Co., Ltd. |
CID000981 |
Japan |
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Korea Zinc Co., Ltd. |
CID002605 |
Korea, Republic of |
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L'Orfebre S.A. |
CID002762 |
Andorra |
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LS-NIKKO Copper Inc. |
CID001078 |
Korea, Republic of |
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LT Metal Ltd. |
CID000689 |
Korea, Republic of |
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Materion |
CID001113 |
United States |
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Matsuda Sangyo Co., Ltd. |
CID001119 |
Japan |
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Metal Concentrators SA (Pty) Ltd. |
CID003575 |
South Africa |
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Metalor Technologies (Hong Kong) Ltd. |
CID001149 |
China |
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Metalor Technologies (Singapore) Pte., Ltd. |
CID001152 |
Singapore |
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Metalor Technologies (Suzhou) Ltd. |
CID001147 |
China |
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Metalor Technologies S.A. |
CID001153 |
Switzerland |
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Metalor USA Refining Corporation |
CID001157 |
United States |
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Metalurgica Met-Mex Penoles S.A. De C.V. |
CID001161 |
Mexico |
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Mitsubishi Materials Corporation |
CID001188 |
Japan |
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Mitsui Mining and Smelting Co., Ltd. |
CID001193 |
Japan |
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MKS PAMP SA |
CID001352 |
Switzerland |
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MMTC-PAMP India Pvt., Ltd. |
CID002509 |
India |
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Nadir Metal Rafineri San. Ve Tic. A.S. |
CID001220 |
Turkey |
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Navoi Mining and Metallurgical Combinat |
CID001236 |
Uzbekistan |
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NH Recytech Company |
CID003189 |
Korea, Republic of |
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Nihon Material Co., Ltd. |
CID001259 |
Japan |
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Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
CID002779 |
Austria |
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Ohura Precious Metal Industry Co., Ltd. |
CID001325 |
Japan |
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Planta Recuperadora de Metales SpA |
CID002919 |
Chile |
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PT Aneka Tambang (Persero) Tbk |
CID001397 |
Indonesia |
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PX Precinox S.A. |
CID001498 |
Switzerland |
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Rand Refinery (Pty) Ltd. |
CID001512 |
South Africa |
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REMONDIS PMR B.V. |
CID002582 |
Netherlands |
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Royal Canadian Mint |
CID001534 |
Canada |
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SAFINA A.S. |
CID002290 |
Czech Republic |
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SEMPSA Joyeria Plateria S.A. |
CID001585 |
Spain |
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Shandong Gold Smelting Co., Ltd. |
CID001916 |
China |
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Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
CID001622 |
China |
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Sichuan Tianze Precious Metals Co., Ltd. |
CID001736 |
China |
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Solar Applied Materials Technology Corp. |
CID001761 |
Taiwan |
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Sumitomo Metal Mining Co., Ltd. |
CID001798 |
Japan |
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SungEel HiMetal Co., Ltd. |
CID002918 |
Korea, Republic of |
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T.C.A S.p.A |
CID002580 |
Italy |
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Tanaka Kikinzoku Kogyo K.K. |
CID001875 |
Japan |
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Tokuriki Honten Co., Ltd. |
CID001938 |
Japan |
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TOO Tau-Ken-Altyn |
CID002615 |
Kazakhstan |
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Torecom |
CID001955 |
Korea, Republic of |
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Umicore S.A. Business Unit Precious Metals Refining |
CID001980 |
Belgium |
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United Precious Metal Refining, Inc. |
CID001993 |
United States |
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Valcambi S.A. |
CID002003 |
Switzerland |
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Western Australian Mint (T/a The Perth Mint) |
CID002030 |
Australia |
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WIELAND Edelmetalle GmbH |
CID002778 |
Germany |
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Yamakin Co., Ltd. |
CID002100 |
Japan |
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Yokohama Metal Co., Ltd. |
CID002129 |
Japan |
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Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
CID002224 |
China |
|
Tantalum |
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|
AMG Brasil |
CID001076 |
Brazil |
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Changsha South Tantalum Niobium Co., Ltd. |
CID000211 |
China |
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D Block Metals, LLC |
CID002504 |
United States |
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F&X Electro-Materials Ltd. |
CID000460 |
China |
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FIR Metals & Resource Ltd. |
CID002505 |
China |
|
Global Advanced Metals Aizu |
CID002558 |
Japan |
|
Global Advanced Metals Boyertown |
CID002557 |
United States |
|
Hengyang King Xing Lifeng New Materials Co., Ltd. |
CID002492 |
China |
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Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
CID002512 |
China |
|
Jiangxi Tuohong New Raw Material |
CID002842 |
China |
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JiuJiang JinXin Nonferrous Metals Co., Ltd. |
CID000914 |
China |
|
Jiujiang Tanbre Co., Ltd. |
CID000917 |
China |
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
CID002506 |
China |
|
KEMET de Mexico |
CID002539 |
Mexico |
|
Materion Newton Inc. |
CID002548 |
United States |
|
Metallurgical Products India Pvt., Ltd. |
CID001163 |
India |
|
Mineracao Taboca S.A. |
CID001175 |
Brazil |
|
Mitsui Mining and Smelting Co., Ltd. |
CID001192 |
Japan |
|
Molycorp Silmet A.S. |
CID001200 |
Estonia |
|
Ningxia Orient Tantalum Industry Co., Ltd. |
CID001277 |
China |
|
QuantumClean |
CID001508 |
United States |
|
Resind Industria e Comercio Ltda. |
CID002707 |
Brazil |
|
RFH Yancheng Jinye New Material Technology Co., Ltd. |
CID003583 |
China |
|
Taki Chemical Co., Ltd. |
CID001869 |
Japan |
|
TANIOBIS Co., Ltd. |
CID002544 |
Thailand |
|
TANIOBIS GmbH |
CID002545 |
Germany |
|
TANIOBIS Japan Co., Ltd. |
CID002549 |
Japan |
|
TANIOBIS Smelting GmbH & Co. KG |
CID002550 |
Germany |
|
Telex Metals |
CID001891 |
United States |
|
Ulba Metallurgical Plant JSC |
CID001969 |
Kazakhstan |
|
XIMEI RESOURCES (GUANGDONG) LIMITED |
CID000616 |
China |
|
XinXing Haorong Electronic Material Co., Ltd. |
CID002508 |
China |
|
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
CID001522 |
China |
|
Tin |
||
|
Alpha |
CID000292 |
United States |
|
Aurubis Beerse |
CID002773 |
Belgium |
|
Aurubis Berango |
CID002774 |
Spain |
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CID000228 |
China |
|
Chifeng Dajingzi Tin Industry Co., Ltd. |
CID003190 |
China |
|
China Tin Group Co., Ltd. |
CID001070 |
China |
|
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
CID003486 |
Brazil |
|
CRM Synergies |
CID003524 |
Spain |
|
CV Ayi Jaya |
CID002570 |
Indonesia |
|
CV Venus Inti Perkasa |
CID002455 |
Indonesia |
|
Dowa |
CID000402 |
Japan |
|
DS Myanmar |
CID003831 |
Myanmar |
|
EM Vinto |
CID000438 |
Bolivia |
|
Estanho de Rondonia S.A. |
CID000448 |
Brazil |
|
Fabrica Auricchio Industria e Comercio Ltda. |
CID003582 |
Brazil |
|
Fenix Metals |
CID000468 |
Poland |
|
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CID000538 |
China |
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
CID003116 |
China |
|
HuiChang Hill Tin Industry Co., Ltd. |
CID002844 |
China |
|
Jiangxi New Nanshan Technology Ltd. |
CID001231 |
China |
|
Luna Smelter, Ltd. |
CID003387 |
Rwanda |
|
Magnu's Minerais Metais e Ligas Ltda. |
CID002468 |
Brazil |
|
Malaysia Smelting Corporation (MSC) |
CID001105 |
Malaysia |
|
Metallic Resources, Inc. |
CID001142 |
United States |
|
Mineracao Taboca S.A. |
CID001173 |
Brazil |
|
Mining Minerals Resources SARL |
CID004065 |
DRC- Congo (Kinshasa) |
|
Minsur |
CID001182 |
Peru |
|
Mitsubishi Materials Corporation |
CID001191 |
Japan |
|
O.M. Manufacturing (Thailand) Co., Ltd. |
CID001314 |
Thailand |
|
O.M. Manufacturing Philippines, Inc. |
CID002517 |
Philippines |
|
Operaciones Metalurgicas S.A. |
CID001337 |
Bolivia |
|
PT Aries Kencana Sejahtera |
CID000309 |
Indonesia |
|
PT Artha Cipta Langgeng |
CID001399 |
Indonesia |
|
PT ATD Makmur Mandiri Jaya |
CID002503 |
Indonesia |
|
PT Babel Inti Perkasa |
CID001402 |
Indonesia |
|
PT Babel Surya Alam Lestari |
CID001406 |
Indonesia |
|
PT Bangka Prima Tin |
CID002776 |
Indonesia |
|
PT Bangka Serumpun |
CID003205 |
Indonesia |
|
PT Belitung Industri Sejahtera |
CID001421 |
Indonesia |
|
PT Bukit Timah |
CID001428 |
Indonesia |
|
PT Cipta Persada Mulia |
CID002696 |
Indonesia |
|
PT Menara Cipta Mulia |
CID002835 |
Indonesia |
|
PT Mitra Stania Prima |
CID001453 |
Indonesia |
|
PT Mitra Sukses Globalindo |
CID003449 |
Indonesia |
|
PT Premium Tin Indonesia |
CID000313 |
Indonesia |
|
PT Prima Timah Utama |
CID001458 |
Indonesia |
|
PT Putera Sarana Shakti (PT PSS) |
CID003868 |
Indonesia |
|
PT Rajawali Rimba Perkasa |
CID003381 |
Indonesia |
|
PT Rajehan Ariq |
CID002593 |
Indonesia |
|
PT Refined Bangka Tin |
CID001460 |
Indonesia |
|
PT Sariwiguna Binasentosa |
CID001463 |
Indonesia |
|
PT Stanindo Inti Perkasa |
CID001468 |
Indonesia |
|
PT Sukses Inti Makmur |
CID002816 |
Indonesia |
|
PT Timah Tbk Kundur |
CID001477 |
Indonesia |
|
PT Timah Tbk Mentok |
CID001482 |
Indonesia |
|
PT Tinindo Inter Nusa |
CID001490 |
Indonesia |
|
PT Tommy Utama |
CID001493 |
Indonesia |
|
Resind Industria e Comercio Ltda. |
CID002706 |
Brazil |
|
Rui Da Hung |
CID001539 |
Taiwan |
|
Super Ligas |
CID002756 |
Brazil |
|
Thaisarco |
CID001898 |
Thailand |
|
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
CID002180 |
China |
|
Tin Technology & Refining |
CID003325 |
United States |
|
White Solder Metalurgia e Mineracao Ltda. |
CID002036 |
Brazil |
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CID002158 |
China |
|
Tungsten |
||
|
Alpha |
CID000292 |
United States |
|
Aurubis Beerse |
CID002773 |
Belgium |
|
Aurubis Berango |
CID002774 |
Spain |
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
CID000228 |
China |
|
Chifeng Dajingzi Tin Industry Co., Ltd. |
CID003190 |
China |
|
China Tin Group Co., Ltd. |
CID001070 |
China |
|
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
CID003486 |
Brazil |
|
CRM Synergies |
CID003524 |
Spain |
|
CV Ayi Jaya |
CID002570 |
Indonesia |
|
CV Venus Inti Perkasa |
CID002455 |
Indonesia |
|
Dowa |
CID000402 |
Japan |
|
DS Myanmar |
CID003831 |
Myanmar |
|
EM Vinto |
CID000438 |
Bolivia |
|
Estanho de Rondonia S.A. |
CID000448 |
Brazil |
|
Fabrica Auricchio Industria e Comercio Ltda. |
CID003582 |
Brazil |
|
Fenix Metals |
CID000468 |
Poland |
|
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
CID000538 |
China |
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
CID003116 |
China |
|
HuiChang Hill Tin Industry Co., Ltd. |
CID002844 |
China |
|
Jiangxi New Nanshan Technology Ltd. |
CID001231 |
China |
|
Luna Smelter, Ltd. |
CID003387 |
Rwanda |
|
Magnu's Minerais Metais e Ligas Ltda. |
CID002468 |
Brazil |
|
Malaysia Smelting Corporation (MSC) |
CID001105 |
Malaysia |
|
Metallic Resources, Inc. |
CID001142 |
United States |
|
Mineracao Taboca S.A. |
CID001173 |
Brazil |
|
Mining Minerals Resources SARL |
CID004065 |
DRC- Congo (Kinshasa) |
|
Minsur |
CID001182 |
Peru |
|
Mitsubishi Materials Corporation |
CID001191 |
Japan |
|
O.M. Manufacturing (Thailand) Co., Ltd. |
CID001314 |
Thailand |
|
O.M. Manufacturing Philippines, Inc. |
CID002517 |
Philippines |
|
Operaciones Metalurgicas S.A. |
CID001337 |
Bolivia |
|
PT Aries Kencana Sejahtera |
CID000309 |
Indonesia |
|
PT Artha Cipta Langgeng |
CID001399 |
Indonesia |
|
PT ATD Makmur Mandiri Jaya |
CID002503 |
Indonesia |
|
PT Babel Inti Perkasa |
CID001402 |
Indonesia |
|
PT Babel Surya Alam Lestari |
CID001406 |
Indonesia |
|
PT Bangka Prima Tin |
CID002776 |
Indonesia |
|
PT Bangka Serumpun |
CID003205 |
Indonesia |
|
PT Belitung Industri Sejahtera |
CID001421 |
Indonesia |
|
PT Bukit Timah |
CID001428 |
Indonesia |
|
PT Cipta Persada Mulia |
CID002696 |
Indonesia |
|
PT Menara Cipta Mulia |
CID002835 |
Indonesia |
|
PT Mitra Stania Prima |
CID001453 |
Indonesia |
|
PT Mitra Sukses Globalindo |
CID003449 |
Indonesia |
|
PT Premium Tin Indonesia |
CID000313 |
Indonesia |
|
PT Prima Timah Utama |
CID001458 |
Indonesia |
|
PT Putera Sarana Shakti (PT PSS) |
CID003868 |
Indonesia |
|
PT Rajawali Rimba Perkasa |
CID003381 |
Indonesia |
|
PT Rajehan Ariq |
CID002593 |
Indonesia |
|
PT Refined Bangka Tin |
CID001460 |
Indonesia |
|
PT Sariwiguna Binasentosa |
CID001463 |
Indonesia |
|
PT Stanindo Inti Perkasa |
CID001468 |
Indonesia |
|
PT Sukses Inti Makmur |
CID002816 |
Indonesia |
|
PT Timah Tbk Kundur |
CID001477 |
Indonesia |
|
PT Timah Tbk Mentok |
CID001482 |
Indonesia |
|
PT Tinindo Inter Nusa |
CID001490 |
Indonesia |
|
PT Tommy Utama |
CID001493 |
Indonesia |
|
Resind Industria e Comercio Ltda. |
CID002706 |
Brazil |
|
Rui Da Hung |
CID001539 |
Taiwan |
|
Super Ligas |
CID002756 |
Brazil |
|
Thaisarco |
CID001898 |
Thailand |
|
Tin Smelting Branch of Yunnan Tin Co., Ltd. |
CID002180 |
China |
|
Tin Technology & Refining |
CID003325 |
United States |
|
White Solder Metalurgia e Mineracao Ltda. |
CID002036 |
Brazil |
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
CID002158 |
China |
Countries of origin that these facilities may source Conflict Minerals include:
L1 - RMI Level 1 Countries are those that are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries, including: Argentina, Armenia, Australia, Austria, Azerbaijan, Bahamas, Barbados, Belarus, Belgium, Benin, Bolivia, Bosnia and Herzegovina, Botswana, Brazil, Bulgaria, Burkina Faso, Cambodia, Cameroon, Canada, Cayman Islands, Chile, China, Colombia, Croatia, Curacao, Cyprus, Czech Republic, Denmark, Dominican Republic, Ecuador, Egypt, El Salvador, Eritrea, Estonia, Ethiopia, Fiji, Finland, France, Gabon, Gambia, Georgia, Germany, Ghana, Greece, Guatemala, Guinea, Guyana, Honduras, Hong Kong, Hungary, Iceland, India, Indonesia, Iran, Ireland, Israel, Italy, Ivory Coast, Japan, Jordan, Kazakhstan, Kenya, Korea, Republic of, Kosovo, Kuwait, Kyrgyzstan, Laos, Latvia, Lebanon, Liberia, Libya, Liechtenstein, Lithuania, Luxembourg, Macau, Madagascar, Malaysia, Mali, Malta, Mauritania, Mauritius, Mexico, Mongolia, Morocco, Myanmar, Namibia, Netherlands, New Caledonia, New Zealand, Nicaragua, Niger, Nigeria, Norway, Pakistan, Panama, Papua New Guinea, Peru, Philippines, Poland, Portugal, Puerto Rico, Romania, Russian Federation, San Marino, Saudi Arabia, Senegal, Serbia, Sierra Leone, Singapore, Slovakia, Solomon Islands, Spain, Suriname, Swaziland, Sweden, Switzerland, Taiwan, Tajikistan, Thailand, Togo, Trinidad and Tobago, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom of Great Britain and Northern Ireland, United States of America, Uruguay, Uzbekistan, Vatican City, Venezuela, Vietnam, Yemen, and Zimbabwe.
L2 - RMI Level 2 Countries are those that are known or plausible countries for smuggling, exporting, or transiting of materials containing tantalum, tin, tungsten, or gold out of conflict affected regions, including: Mozambique and South Africa.
L3 - RMI Level 3 Countries are those high-risk countries outlined in Section 1502 of the Dodd-Frank Act as those affected or bordering conflict-affected regions: currently defined as the Democratic Republic of Congo (DRC) and its nine adjoining countries (Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia).
Future Steps
We have communicated our expectations, as reflected in our Conflict Minerals Policy, to our contract manufacturers and other suppliers. We have continued to engage with our Tier 1 suppliers to update their information on the source and chain of custody of conflict minerals in our supply chain and to require that all smelters utilized agree to participate in the Responsible Minerals Assurance Process or equivalent program.
Forward-Looking Statements
Statements relating to risk mitigation and certain other statements herein are forward-looking in nature and are based on the Company's management's current expectations or beliefs. Furthermore, our reporting obligations under the conflict minerals rules may change in the future and our ability to implement certain processes or obtain information from our suppliers may differ materially from those anticipated or implied in this report. These forward-looking statements are not a guarantee of performance and are subject to a number of uncertainties and other factors that may be outside of the Company's control and that could cause actual events to differ materially from those expressed or implied by the statements made herein. The Company assumes no obligation to update or provide revisions to any forward-looking statements.
Documents Incorporated by Reference
Unless otherwise stated herein, any documents, third-party materials or references to websites (including QuickLogic's) are not incorporated by reference in, or considered to be a part of, this Report, unless expressly incorporated by reference herein.