Delaware | 1-12696 | 77-0207692 |
(State or Other Jurisdiction of Incorporation) | (Commission file number) | (I.R.S. Employer Identification No.) |
Not Applicable |
(Former name or former address, if changed since last report) |
S | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014. |
1) | Recycled or scrap material. |
2) | Countries with known active ore production that are not identified as conflict regions. |
3) | Known or possible countries for smuggling or export of minerals out of the DRC. |
4) | The DRC and adjoining countries. |
Exhibit Number | Description |
Date: May 29, 2015 | PLANTRONICS, INC. | ||
By: | /s/ Pamela Strayer | ||
Name: | Pamela Strayer | ||
Title: | Senior Vice President and Chief Financial Officer |
1. | Establish Strong Company Management Systems |
• | Plantronics has a company Conflict Minerals team consisting of representatives from the Compliance, Legal, Operations/Materials, Quality and Supplier Quality Engineering departments. |
• | Plantronics has a conflict minerals policy statement publicly available at http://www.plantronics.com/us/company/corporate-governance/conflict-minerals.jsp. |
• | We maintain a grievance reporting system open to both employees and suppliers through our ethics reporting system. |
• | In addition to any annual survey using the CMRT, supplier obligations and requirements in this regard have been incorporated into the Supplier Code of Conduct, which is available on the corporate governance section of our website. In addition, Conflict Minerals Requirements, including due diligence and participation in annual supplier survey, are included in our controlled “Purchasing & Supplier Management” methods and procedures document. |
• | Plantronics establishes and maintains long term relationships with the majority of our first tier Original Design, Contract, and Custom Part Manufacturers to facilitate engagement with suppliers to improve due diligence performance. |
• | Since we do not have direct relationships with any facilities processing 3TG, we are an active participant in the Conflict Free Sourcing Initiative (CFSI) (http://www.conflictfreesourcing.org/about/members-and-collaborations/) to aid the development of conflict free supply chains at the smelter or refiner level and further upstream. |
• | Conflict Minerals materials records are included in our records retention policy. |
• | The Conflict Minerals Team issues a formal report of progress and findings to upper management quarterly. |
• | We created a controlled Methods and Procedures document regarding Conflict Minerals Due Diligence Procedures. |
• | For CY2014 we purchased and installed a software tool to improve management and auditability of supplier communications, as well as to receive, evaluate, store, and determine statistics on incoming CMRTs. |
• | In CY2014 we conducted Conflict Minerals assessments during new supplier qualifications. |
2. | Identified and Assessed Risk in the Supply Chain |
• | We conducted a supplier survey of all direct first tier suppliers providing products or components within scope of the rule; necessary for the functionality of our products and likely to contain 3TG. The survey required that the supplier return the then current version of the CMRT (3.0x). The request included information to inform the suppliers of Plantronics’ Conflict Minerals Rule reporting obligations as well as the assistance required from our supply chain, and the resulting expectations for the sourcing of conflict minerals. |
• | Reminders, late notices and finally delinquent notices were sent to non-responsive suppliers. Commodity Mangers were involved in escalation at the time of the delinquent notices. We did not find it necessary to restrict business or disengage from any supplier due to failure to respond to the survey. |
• | All incoming CMRTs underwent a two-step review process. The first step is a PASS/FAIL check by our Conflict Minerals software for completeness and internal consistency of the declaration and submitted smelter list. A message was automatically sent by the system to suppliers submitting CMRTs containing errors with an explanation of the error and a request for corrective action and re-submission. |
• | Once CMRTs passed this first evaluation, they were then evaluated by internal compliance engineers on an ACCEPT/MODIFY basis for consistency with the known content and complexity of the products or components provided. A message was sent to suppliers submitting CMRTs found insufficient or incomplete with an explanation and request for corrective action. We continued to communicate with those suppliers to improve the content and quality of their responses. |
• | In addition, we used a data mining service to obtain conflict minerals information, also using the CFSI CMRT, from manufacturers of off-the-shelf components with whom we had no direct relationship. |
• | Facilities processing 3TG reported by the supply chain were categorized, based on information available through CFSI, as |
◦ | Legitimate Smelters or Refiners (“SORs”), |
◦ | Entities known to Not be legitimate SORs. |
◦ | Alleged SORs - those whose status as a legitimate SOR had not been determined and required further investigation. |
• | In addition to SORs known to, or believed to, source from the covered countries who were not validated as conflict free, Plantronics identified alleged SORs and non-smelters as a source of risk, since the actual source of the 3TG is not known. |
3. | Designed and Implemented a Strategy to Respond to Identified Risks |
• | We have conducted research into “alleged” SORs reported in our supplier survey to determine the nature of these entities’ business. This effort is done both through collaborative efforts in CFSI, and our own independent research in areas where we have associates that speak the local language. Through these efforts the number of “alleged” SORs has been reduced significantly from the number in CY2013. |
• | We also asked suppliers reporting non-smelters or alleged smelters to verify the information and if possible, identify actual smelters. We gave feedback concerning the actual nature of a non-smelter’s business to the supplier when such information was available, primarily through CFSI collaborative efforts. |
• | We added Conflict Minerals requirements to new supplier assessment and existing supplier audit procedures. |
• | To better communicate the issues and requirements, we conducted in person and teleconference training with suppliers in Asia. |
• | We continued to work within CFSI teams to determine the legitimacy of alleged smelters reported by our supply chain. We encouraged known smelters not yet validated as Conflict Free to participate in Conflict Free Smelter Program (CFSP). |
4. | Carry out independent 3rd Party Audit of Smelters’/Refiners’ Due Diligence Practices |
• | Because Plantronics has no direct business relationships with smelters, we worked within industry initiatives to implement validation of DRC conflict free smelters as outlined in OECD Guidance for downstream companies. We relied on the results of audits conducted by CFSP to determine smelters’ Due Diligence Practices. As an active contributing member of the CFSI, we actively participated in outreach to confirmed smelters to encourage participation in CFSP. |
5. | Report Annually on Supply Chain Due Diligence |
• | Our Form SD and this Report together constitute our annual report on our Conflict Minerals Due Diligence. These have been filed with the SEC and are available on our website at www.plantronics.com/conflictminerals. |
• | Most of our direct supplier responses represented their supply chain at a company-level rather than being product-specific. Therefore, the list of processing facilities contained in this report may contain more facilities than those that actually process the conflict minerals contained in our products. The total number or unique entities reported as smelters or refiners by the Plantronics supplier base as result of CY 2014 Supplier Survey was 310. Of these, 228 have been confirmed as being legitimate SORs by the CFSI, 56 are known to not be legitimate SORs, and the status of 26 could not be confirmed as of our cutoff date of April 30, 2015. |
• | Of the 228 SORs reported by the supplier base, 140 had been validated by CFSP as being in conformance with a CFSP recognized conflict free audit protocol (CFSP, London Bullion Market Association, or Responsible Jewelry Council). Another 45 were in process or communication with CFSP, or participating in another recognized program, but had not achieved validated status as of April 30, 2015. |
• | The remaining legitimate smelters require outreach to encourage participation in a conflict free program. Plantronics actively participates in CFSI targeted outreach through email and, in countries where we have associates that speak the local language, telephone calls. We have expressed a willingness to interact directly with selected smelters to help guide them through the CFSP audit process. |
• | Of the 228 legitimate SORs reported by the supplier base, we determined during RCOI that there was no reason to believe that 68 of the SORs sourced or may have sourced any minerals from the covered countries. |
• | Of the remaining smelters with definitive RCOI information available through CFSI or other publicly available information, 19 were known or reasonably believed to source minerals from the DRC, the surrounding countries or countries known as possible routes for smuggling or export of minerals out of the DRC. All 19 are CFSP validated. The facilities not eliminated during RCOI, along with the location of the facility and the conflict free status are listed in Table I. The countries believed to be the source of 3TG in our products are listed in Table II. |
• | While we did not find any information that would give us reason to believe armed groups directly or indirectly benefitted as a result of the mining, transport for processing of 3TG in our products, the smelter information collected from our suppler base included non-smelters and alleged smelters, as well as a number of legitimate smelters or refiners that had not been audited and validated as DRC Conflict Free by the CFSP, or any other recognized organization. For these reasons, we are unable to determine that any of our products or product categories are DRC Conflict Free. |
• | Include a hyperlink to our Conflict Minerals Policy in the supplier survey request email. |
• | Improve the content of suppliers’ responses through continued training and education. |
• | Introduce the use of on-site visits, process audits, and document examination to validate supplier responses. |
• | Increase the number of off-the-shelf part manufacturers from whom conflict minerals data is obtained. |
• | Maintain membership and active participation within CFSI, conducting research into smelter operations, sourcing and compliance. Continue to conduct coordinated outreach to encourage more smelters to participate in recognized conflict free validation programs such as the Conflict Free Smelter Program. |
• | Engage directly with selected smelters to help guide them through the CFSP audit process. |
• | Encourage our supply chain to use validated conflict free smelters, in particular those sourcing responsibly within the DRC and adjoining countries, to the greatest extent possible. |
Metal | Smelter Name | Country | Conflict Free Status |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Validated |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Validated |
Gold | Argor-Heraeus SA | SWITZERLAND | Validated |
Gold | Asaka Riken Co Ltd | JAPAN | On CFSP Active List |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Validated |
Gold | Aurubis AG | GERMANY | Validated |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | |
Gold | Bauer Walser AG | GERMANY | |
Gold | Boliden AB | SWEDEN | Validated |
Gold | C. Hafner GmbH + Co. KG | GERMANY | Validated |
Gold | CCR Refinery – Glencore Canada Corporation | CANADA | Validated |
Gold | Cendres + Métaux SA | SWITZERLAND | On CFSP Active List |
Gold | Chimet S.p.A. | ITALY | Validated |
Gold | Chugai Mining | JAPAN | |
Gold | Daejin Indus Co. Ltd | KOREA, REPUBLIC OF | |
Gold | Do Sung Corporation | KOREA, REPUBLIC OF | |
Gold | Doduco | GERMANY | On CFSP Active List |
Gold | FSE Novosibirsk Refinery | RUSSIAN FEDERATION | |
Gold | Guangdong Jinding Gold Limited | CHINA |
Metal | Smelter Name | Country | Conflict Free Status |
Gold | Guoda Safina High-Tech.Environmental Refinery Co.,Ltd | CHINA | |
Gold | Heraeus Ltd. Hong Kong | HONG KONG | Validated |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Validated |
Gold | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | |
Gold | Hwasung CJ Co. Ltd | KOREA, REPUBLIC OF | |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA | |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Validated |
Gold | Istanbul Gold Refinery | TURKEY | Validated |
Gold | Japan Mint | JAPAN | Validated |
Gold | Jiangxi Copper Company Limited | CHINA | |
Gold | Johnson Matthey Inc | UNITED STATES | Validated |
Gold | Johnson Matthey Ltd | CANADA | Validated |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Validated |
Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Validated |
Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Validated |
Gold | Kazzinc Ltd | KAZAKHSTAN | Validated |
Gold | Kennecott Utah Copper LLC | UNITED STATES | Validated |
Gold | Korea Metal Co. Ltd | KOREA, REPUBLIC OF | |
Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | |
Gold | L' azurde Company For Jewelry | SAUDI ARABIA | Validated |
Gold | Lingbao Gold Company Limited | CHINA | |
Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | CHINA | |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | Validated |
Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG | Validated |
Gold | Metalor Technologies (Singapore) Pte. Ltd. | SINGAPORE | Validated |
Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | |
Gold | Metalor Technologies SA | SWITZERLAND | Validated |
Gold | Metalor USA Refining Corporation | UNITED STATES | Validated |
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO | Validated |
Gold | Mitsubishi Materials Corporation | JAPAN | Validated |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Validated |
Metal | Smelter Name | Country | Conflict Free Status |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Validated |
Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | |
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | RUSSIAN FEDERATION | Validated |
Gold | OJSC Kolyma Refinery | RUSSIAN FEDERATION | |
Gold | PAMP SA | SWITZERLAND | Validated |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Validated |
Gold | PX Précinox SA | SWITZERLAND | Validated |
Gold | Rand Refinery (Pty) Ltd | SOUTH AFRICA | Validated |
Gold | Sabin Metal Corp. | UNITED STATES | |
Gold | SAMWON METALS Corp. | KOREA, REPUBLIC OF | |
Gold | Schone Edelmetaal | NETHERLANDS | Validated |
Gold | SEMPSA Joyería Platería SA | SPAIN | Validated |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | |
Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | CHINA | Validated |
Gold | So Accurate Group, Inc. | UNITED STATES | |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | On CFSP Active List |
Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Validated |
Gold | The Great Wall Gold and Silver Refinery of China | CHINA | |
Gold | The Refinery of Shandong Gold Mining Co. Ltd | CHINA | Validated |
Gold | Tokuriki Honten Co., Ltd | JAPAN | Validated |
Gold | Tongling nonferrous Metals Group Co.,Ltd | CHINA | |
Gold | Torecom | KOREA, REPUBLIC OF | On CFSP Active List |
Gold | Umicore Brasil Ltda | BRAZIL | Validated |
Gold | Umicore Precious Metals Thailand | THAILAND | Validated |
Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM | Validated |
Gold | Valcambi SA | SWITZERLAND | Validated |
Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Validated |
Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Validated |
Gold | Yokohama Metal Co Ltd | JAPAN | On CFSP Active List |
Metal | Smelter Name | Country | Conflict Free Status |
Gold | Yunnan Copper Industry Co Ltd | CHINA | |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Validated |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Validated |
Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Validated |
Tantalum | Duoluoshan | CHINA | Validated |
Tantalum | F&X Electro-Materials Ltd. | CHINA | Validated |
Tantalum | Global Advanced Metals | UNITED STATES | Validated |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES | Validated |
Tantalum | H.C. Starck GmbH Goslar | GERMANY | Validated |
Tantalum | H.C. Starck Group | GERMANY | Validated |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Validated |
Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Validated |
Tantalum | KEMET Blue Metals | MEXICO | Validated |
Tantalum | KEMET Corp. | UNITED STATES | Validated |
Tantalum | King-Tan Tantalum Industry Ltd | CHINA | Validated |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Validated |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Validated |
Tantalum | Zhuzhou Cement Carbide | CHINA | Validated |
Tin | China Tin Group Co., Ltd. | CHINA | On CFSP Active List |
Tin | CNMC (Guangxi) PGMA Co. Ltd. | CHINA | |
Tin | Cooperativa Metalurgica de Rondônia Ltda.a | BRAZIL | Validated |
Tin | CV Makmur Jaya | INDONESIA | |
Tin | CV Serumpun Sebalai | INDONESIA | On CFSP Active List |
Tin | Feinhütte Halsbrücke GmbH | GERMANY | |
Tin | Fenix Metals | POLAND | On CFSP Active List |
Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | |
Tin | Gejiu Zi-Li | CHINA | |
Tin | Huichang Jinshunda Tin Co. Ltd | CHINA | |
Tin | Linwu Xianggui Smelter Co | CHINA | |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Validated |
Metal | Smelter Name | Country | Conflict Free Status |
Tin | Metallic Resources Inc | USA | On CFSP Active List |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd | CHINA | |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | On CFSP Active List |
Tin | Novosibirsk Integrated Tin Works | RUSSIAN FEDERATION | |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | On CFSP Active List |
Tin | PT Alam Lestari Kencana | INDONESIA | |
Tin | PT Aries Kencana Sejahtera | INDONESIA | On CFSP Active List |
Tin | PT Artha Cipta Langgeng | INDONESIA | On CFSP Active List |
Tin | PT Babel Surya Alam Lestari | INDONESIA | |
Tin | PT Bangka Kudai Tin | INDONESIA | |
Tin | PT Bangka Timah Utama Sejahtera | INDONESIA | |
Tin | PT BilliTin Makmur Lestari | INDONESIA | On CFSP Active List |
Tin | PT Fang Di MulTindo | INDONESIA | |
Tin | PT HP Metals Indonesia | INDONESIA | |
Tin | PT Inti Stania Prima | INDONESIA | On CFSP Active List |
Tin | PT JusTindo | INDONESIA | On CFSP Active List |
Tin | PT Karimun Mining | INDONESIA | On CFSP Active List |
Tin | PT Koba Tin | INDONESIA | |
Tin | PT Pelat Timah Nusantara Tbk | INDONESIA | |
Tin | PT Sumber Jaya Indah | INDONESIA | On CFSP Active List |
Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Validated |
Tin | PT Yinchendo Mining Industry | INDONESIA | |
Tin | Rui Da Hung | TAIWAN | On CFSP Active List |
Tin | Soft Metais, Ltda. | BRAZIL | Validated |
Tin | Thaisarco | THAILAND | Validated |
Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | CHINA | On CFSP Active List |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Progressing Toward CFSP Validation |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Validated |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Progressing Toward CFSP Validation |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Progressing Toward CFSP Validation |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Validated |
Metal | Smelter Name | Country | Conflict Free Status |
Tungsten | Ganzhou Grand Sea W & Mo Group Co Ltd | CHINA | Validated |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA | Progressing Toward CFSP Validation |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Progressing Toward CFSP Validation |
Tungsten | H.C. Starck GmbH | GERMANY | Progressing Toward CFSP Validation |
Tungsten | H.C. Starck Group | GERMANY | Progressing Toward CFSP Validation |
Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA | Progressing Toward CFSP Validation |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Progressing Toward CFSP Validation |
Tungsten | Kennametal Fallon | UNITED STATES | Progressing Toward CFSP Validation |
Tungsten | Kennametal Huntsville | UNITED STATES | Progressing Toward CFSP Validation |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Progressing Toward CFSP Validation |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | VIET NAM | Validated |
Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Validated |
Tungsten | WOLFRAM Company, CJSC | RUSSIAN FEDERATION | Progressing Toward CFSP Validation |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Validated |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | On CFSP Active List |
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