EX-1.01 2 cy17cmrex101.htm EXHIBIT 1.01 Exhibit


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PLANTRONICS, INC.
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2017

Introduction

This This Conflict Minerals Report for the calendar year ended December 31, 2017 (“CY 2017”) is presented by Plantronics, Inc. ("Plantronics", “we” or the “Company”) to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Exchange Act”).

Plantronics is a global company that manufactures, and contracts to manufacture communications headsets and related equipment, as listed on our Form SD of which this report is a part, from a global supply chain with many levels. We work with our supplier base to identify the facilities processing Tin, Tantalum, Tungsten and Gold (3TG) in our supply chain.

As part of the RCOI described in Form SD, Plantronics performed a supplier survey using the Conflict Free Sourcing Initiative (RMI) Conflict Minerals Reporting Template (CMRT) during the second half of CY 2017. Eighty-one direct first tier suppliers providing components used in Plantronics products within scope of the rule as described further in the Form SD were included in the survey utilized for both RCOI and Due Diligence. The information obtained in the survey indicated that there was reason to believe that a portion of the 3TG used in Plantronics products may have originated in the Democratic Republic of Congo or the adjoining countries (the “covered countries”) and were not exclusively from scrap or recycled sources, triggering the due diligence steps described in the following sections.

Design and Execution of Due Diligence

We designed and implemented the majority of our due diligence measures in preparation for the reporting year CY 2013 with incremental modifications made over time to improve and refine the process, such as implementing supplier survey software and conducting onsite supplier audits. These measures were continued in CY 2017 and are described herein. These measures are designed to conform, in all material respects, to the framework in The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD 2012) including the Supplement on Tin, Tantalum and Tungsten, as well as those portions of the OECD Supplement on Gold applicable to downstream companies (collectively the “OECD Guidance”). In accordance with the five step OECD Guidance, our measures are designed to determine, to the best of our ability, the source of the 3TG materials necessary for the functionality and/or production of our products, to ascertain if the materials originated in one of the covered countries, and if so, whether armed groups directly or indirectly benefited as a result.

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 https://www.plantronics.com/us/en/about/corporate-responsibility/product-stewardship.






Plantronics maintains a grievance reporting system open to both employees and suppliers through our ethics reporting system at https://www.plantronics.com/us/en/about/corporate-responsibility/product-stewardship. Alternatively, grievances specifically relating to Conflict Minerals may be submitted directly to RMI at http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.

In addition to any annual survey using the CMRT, supplier obligations and requirements 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 an annual supplier survey, are included in our controlled “Purchasing & Supplier Management” methods and procedures document.

Plantronics purchase orders and contracts include a supplier Conflict Minerals Due Diligence expectations clause.

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 have limited direct relationships with any facilities processing 3TG, we are an active participant in the Conflict Free Sourcing Initiative (RMI) (http://www.responsiblemineralsinitiative.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 maintained pursuant to our records retention policy.

The Conflict Minerals Team includes a section that provides information regarding conflict minerals program progress and findings to upper management in a formal quarterly compliance report.

We created a controlled Methods and Procedures document regarding Conflict Minerals Due Diligence Procedures.

Since CY2014 we have used a software tool to improve management and auditability of supplier communications, as well as to request, receive, evaluate, store, and determine statistics on incoming CMRTs. The software is linked to the RMI database and is regularly updated regarding smelter and refiner operational status, conformance to third party audit standards, as well as RCOI information.

Starting in CY 2015 our supplier quality team has conducted Conflict Minerals Ongoing Compliance surveys of selected first tier suppliers’ conflict minerals due diligence programs. Suppliers were selected based on the criticality of components to Plantronics products and the amount of 3TG likely present and the number of 3TG processing facilities in their supply chain, based on previous years’ surveys. These suppliers were primarily Original Design Manufacturers (ODMs) and cable or transducer suppliers. These surveys assessed policy, training, record retention and data validation. Seven such surveys were performed in 2017, two of the surveys found supplier deficiencies which were addressed by corrective action plans, both of which were successfully completed. In addition, any new suppliers being considered for components or products must also undergo the Conflict Minerals Compliance Survey to be approved.

2. Identified and Assessed Risk in the Supply Chain

Prior to conducting the CY2017 supplier survey Plantronics conducted face to face one-on-one training with newly qualified critical component or product suppliers. Training was primarily focused on ensuring a complete smelter list by proper scoping of products and components to identify all likely locations of 3TG, including parts and components purchased by the 1st tier supplier.

We conducted a supplier survey of the 81 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 (5.0x or higher). Our





request included information to inform the suppliers of Plantronics’ reporting obligations under the Conflict Minerals Rule as well as the assistance required from our supply chain, and the resulting expectations for the sourcing of conflict minerals. A link to the Plantronics’ Conflict Minerals policy was included in the request.

Reminders, late notices and delinquent notices were sent to non-responsive suppliers. Commodity Managers were involved in escalation at the time of the delinquent notices. While we did not find it necessary to restrict business or disengage from any currently active suppliers due to failure to respond to the survey, a number of suppliers used only for Clarity products were not responsive, as the survey was done following the sale of the Clarity business and Plantronics no longer has a relationship with these suppliers.

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 software 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. Other than Clarity suppliers, greater than 95% of the suppliers responded by returning a CMRT, and eventually 98% of those responses were accepted after review and, in some cases, correction.

In addition to direct suppliers, we used a data mining service to obtain conflict minerals information, also using the RMI CMRT, from manufacturers of critical and high usage off-the-shelf components with whom we had no direct relationship.

Facilities processing 3TG reported by our supply chain were categorized, based on information available through RMI, as:

Legitimate Smelters or Refiners (SORs).
Entities determined to not be legitimate or active SORs during the reporting period.
Entities alleged to be SORs, whose business could not be determined during the reporting period.

In addition to SORs known to, or believed to, source from the covered countries who were not validated as conflict free, Plantronics identified non-legitimate or alleged 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 continuously conducted research into “alleged” SORs - companies reported that were not on any list of known SORs- reported in our supplier survey to determine the nature of these entities’ business. This effort is done both through collaborative efforts in RMI, and our own independent research in areas where we have associates that speak the local language. Through these efforts the final number of “alleged” SORs has been significantly reduced progressively from the number in previous reporting years, from 83 in CY2013 to 46 in CY2014 to none in CY 2015, CY2016, and CY2017 final survey results. This is attributable to determining that many of the alleged SORs were indeed legitimate SORs or legitimate SOR aliases, or determination of the company’s actual business, as well as improved supplier reporting.

We asked suppliers initially 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 RMI collaborative efforts.






We continued to work within RMI teams to determine the legitimacy of any “alleged SORs” reported by our supply chain or other RMI members.

We encouraged known smelters not yet validated as Conflict Free to participate in Conflict Free Smelter Program (CFSP).

We conducted outreach in coordination with RMI to encourage legitimate SORs reported by our supply chain that have not been validated as DRC conflict free by a recognized conflict free program such as Conflict Free Smelter Program, London Bullion Market Association, Responsible Jewelry Council or TI-CMC, to enter such a program.

4. Carry out independent 3rd Party Audit of Smelters’/Refiners’ Due Diligence Practices

Because Plantronics has few 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.

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 https://www.plantronics.com/us/en/about/corporate-responsibility/product-stewardship.

Results of due diligence performed

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 of unique entities reported as smelters or refiners by the Plantronics supplier base as result of CY 2017 Supplier Survey was 320. Of these, 309 have been confirmed as being legitimate operating SORs by RMI., 11 are known to not be legitimate operational SORs, and there were no reported entities whose status could not be confirmed as of our cutoff date of May 01, 2018.

Of the 309 legitimate SORs reported by the supplier base, 250 had been validated as being in conformance with a RMI recognized conflict free audit protocol (RMAP, London Bullion Market Association, or Responsible Jewelry Council). Another 13 were in process or communication with CFSP, or participating in another recognized program, but had not achieved validated status as of May 04, 2018.

Forty six legitimate reported SORs are not participating in a compliance scheme and have status of “Not Validated” fall into three categories:

Outreach required: (28) Have not yet been convinced to participate, but efforts to encourage them should continue.
Communication Suspended (not interested): (7) Have stated clearly that they do not want to participate.
Communication Suspended (temporarily not operating): (1) Not currently operating, but intend to re-start.

Other Listed Status Categories are:

Non-conformant: (6) Do not conform, failed audit, did not complete re-audit or corrective action in a timely manner.
Due Diligence required: (4) There may be issues other than DRC conflict involved.






The 11 entities reported by our supply chain that are not currently considered legitimate smelters had all been classified as operating smelters and listed on the CMRT at some point. They were reclassified by RMI due to either a change in their business operations or they either temporarily or permanently suspended operations. A number of these smelters currently listed as not legitimate may have been in operation for part of CY2017, so are included on the smelter list. Where information is available as to when they ceased operations, it is noted.

The remaining legitimate smelters that are not conformant as yet require outreach to encourage participation in a conflict free program. Plantronics actively participates in RMI targeted outreach through email and, in countries where we have associates that speak the local language, telephone calls. We also interact directly with selected smelters to help guide them through the CFSP audit process.

Of the 309 legitimate SORs reported by the supplier base, we determined during RCOI that there was no reason to believe that 146 of the SORs sourced or may have sourced any minerals from the covered countries.

Of the remaining smelters with definitive RCOI information available through RMI or other publicly available information, 22 were known or reasonably believed to directly or indirectly 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 22 are RMAP Conformant. 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.

Although the number of SORs reported by our supply chain that have not been validated as conflict free has decreased year over year, the smelter information collected from our suppler base continued to include a number of legitimate smelters or refiners that had not been audited and validated as DRC Conflict Free by the RMAP, or any other recognized organization. The existence of such facilities in our supply chain is sufficient to prevent us from declaring with certainty that no armed groups directly or indirectly benefitted as a result of the mining, transport for processing of 3TG in our products. For these reasons, we are unable to determine that any of our products or product categories are DRC Conflict Free.

During CY 2017 and CY 2018 to date, Plantronics has become of aware of OECD Annex II risks in the 3TG supply chain unrelated to financing conflict in the DRC and adjoining countries. These risks include, but are not limited to, material sourced in conflict risk areas other than the DRC, smelters in countries under sanction or wholly or partially owned by individuals under sanction, or securing raw materials from sanctioned entities. Other concerns are child or forced labor and money laundering. There are some SORs on CY2017 smelter list that may require further due diligence.


Steps to be taken to further mitigate risk

We intend to take the following steps to build on momentum established in the past three years to improve the due diligence conducted, and to further mitigate the risk that the necessary conflict minerals in our products benefit armed groups in the Covered Countries:

In Co-ordination with RMI, engage directly with selected smelters to help guide them through the CFSP audit process. To the extent possible, attend metals industry conferences in conjunction with RMI to use direct contact to encourage participation in validation efforts.

Take advantage of added RMI resources by adding a link on our website to RMI conflict minerals specific grievance system in addition to the existing PLT company grievance system, and utilize the RMI incident reporting tool to evaluate risk and red flags in upstream supply chain.

Strongly encourage our supply chain to source only from validated conflict free smelters, in particular those sourcing responsibly within the DRC and adjoining countries, to the greatest extent possible.






Work with our supply chain to reduce or discontinue sourcing materials from SORs that have consistently refused to participate in any conflict free programs, or SORs that have failed audits or declined to undergo re-audits.

Engage a third party audit to validate status of selected suppliers who report only validated conflict free smelters in their supply chain and who have also passed Conflict Minerals process survey by Plantronics Supplier Engineering team.

Develop policies and practices to address supply chain issues not related to DRC conflict that have been revealed during the Conflict Minerals Supply Chain Survey and participation in RMI activities.


Table I. Plantronics Smelter List

The list of reported SORs is as of May 1, 2018 and Status and RCOI data is from RMI as of May 17, 2018. The list includes SORs that are either known to obtain at least some minerals from the covered countries or are SORs where the source of the minerals was not disclosed and could not be determined. Gold refiners validated as conflict free through LBMA or RJC are included in this list, since they are not required to disclose the country of origin of their minerals. The list does not include those SORs that source only from outside the covered countries as determined through RCOI, or process only recycled or scrap materials. As the majority of our suppliers responded to surveys at a company level rather than with respect to specific products, and due to the complexity of the electronics supply chain, as well as the diversity of both our products and our suppliers’ products, we cannot conclude with certainty that material from all of the smelters reported by our supply chain and included in this report are actually contained in Plantronics’ products.
“Country” refers to the location of the facility, not the source of minerals. The smelter location was not used for RCOI, since it does not necessarily determine the source of the ore, although smelter location near abundant mineral resources can be an indicator of mineral sourcing.

Status is defined as:

Conformant: Smelters or refiners that have been audited and have been validated as compliant with the RMAP Smelter Program or cross recognized (LBMA, RJC) assessment protocols. This includes SORs that were compliant as of 12/31/2017 as well as SORs that have completed audits and become conformant in 2018 prior to filing.

On RMI Active list: Smelters and refiners on the Active list have committed to undergo a CFSP Audit.

Not Validated: Legitimate Smelters or refiners who have not yet completed a CFSP or cross recognized audit validating a conflict free process. This status includes Smelters who have indicated that they do not want to participate in a recognized validation system. Most claim the reason to be that they process only scrap or ore from their own mines and do not source ore from the covered countries. While this may be true, with no audit for verification, they are considered as “may source from covered countries”.

Not a Legitimate Smelter: Entities that were at one time considered to be SORs eligible for an audit, but are no longer in that category, either due to a change in business or operational status.

Non-Conformant: Smelters or refiners that failed RMAP audit or have previously been audited and have been validated as conformant with the RMAP Smelter Program or cross recognized (LBMA, RJC) assessment protocols, but have not undergone a re-audit within the required time frame.

Metal
Smelter Name
Location of smelter
Status
Audit By
Gold
Al Etihad Gold Refinery DMCC
UNITED ARAB EMIRATES
Conformant
RMAP
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Conformant
RJC
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
Conformant
LBMA





Metal
Smelter Name
Location of smelter
Status
Audit By
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Conformant
LBMA
Gold
Argor-Heraeus S.A.
SWITZERLAND
Conformant
LBMA
Gold
Asahi Refining Canada Ltd.
CANADA
Conformant
LBMA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Conformant
LBMA
Gold
AU Traders and Refiners
SOUTH AFRICA
Conformant
RJC
Gold
Aurubis AG
GERMANY
Conformant
LBMA
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Conformant
LBMA
Gold
Boliden AB
SWEDEN
Conformant
LBMA
Gold
C. Hafner GmbH + Co. KG
GERMANY
Conformant
RJC
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Conformant
LBMA
Gold
Cendres + Metaux S.A.
SWITZERLAND
Conformant
LBMA
Gold
Chimet S.p.A.
ITALY
Conformant
LBMA
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
Conformant
LBMA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
Conformant
LBMA
Gold
Heimerle + Meule GmbH
GERMANY
Conformant
LBMA
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Conformant
LBMA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Conformant
LBMA
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Conformant
LBMA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Conformant
LBMA
Gold
Istanbul Gold Refinery
TURKEY
Conformant
LBMA
Gold
Italpreziosi
ITALY
Conformant
RJC
Gold
Japan Mint
JAPAN
Conformant
LBMA
Gold
Jiangxi Copper Co., Ltd.
CHINA
Conformant
LBMA
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Conformant
LBMA
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Conformant
LBMA
Gold
Kazzinc
KAZAKHSTAN
Conformant
LBMA
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Conformant
RJC
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
Conformant
LBMA
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
Conformant
LBMA
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
Conformant
LBMA
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
Conformant
RJC
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
Conformant
RJC
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
Conformant
RJC
Gold
Metalor Technologies S.A.
SWITZERLAND
Conformant
RJC





Metal
Smelter Name
Location of smelter
Status
Audit By
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
Conformant
RJC
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Conformant
LBMA
Gold
Mitsubishi Materials Corporation
JAPAN
Conformant
LBMA
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
RMAP
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
Conformant
LBMA
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Conformant
LBMA
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Conformant
LBMA
Gold
Nihon Material Co., Ltd.
JAPAN
Conformant
LBMA
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
Conformant
RJC
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Conformant
LBMA
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
Conformant
LBMA
Gold
PAMP S.A.
SWITZERLAND
Conformant
LBMA
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
Conformant
LBMA
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
Conformant
LBMA
Gold
PX Precinox S.A.
SWITZERLAND
Conformant
LBMA
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
Conformant
LBMA
Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
Conformant
RJC
Gold
Royal Canadian Mint
CANADA
Conformant
LBMA
Gold
SAAMP
FRANCE
Conformant
RJC
Gold
Safimet S.p.A
ITALY
Conformant
RJC
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Conformant
LBMA
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Conformant
LBMA
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
Conformant
LBMA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Conformant
LBMA
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Conformant
LBMA
Gold
T.C.A S.p.A
ITALY
Conformant
LBMA
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Conformant
LBMA
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Conformant
LBMA
Gold
Tokuriki Honten Co., Ltd.
JAPAN
Conformant
LBMA
Gold
Umicore Brasil Ltda.
BRAZIL
Conformant
LBMA
Gold
Umicore Precious Metals Thailand
THAILAND
Conformant
LBMA
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Conformant
LBMA
Gold
Valcambi S.A.
SWITZERLAND
Conformant
RJC
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Conformant
LBMA





Metal
Smelter Name
Location of smelter
Status
Audit By
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Conformant
LBMA
Tantalum
F&X Electro-Materials Ltd.
CHINA
Conformant
RMAP
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Conformant
RMAP
Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
Conformant
RMAP
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Conformant
RMAP
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Conformant
RMAP
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Conformant
RMAP
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Conformant
RMAP
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Conformant
RMAP
Tantalum
KEMET Blue Metals
MEXICO
Conformant
RMAP
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA
Conformant
RMAP
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Conformant
RMAP
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Conformant
RMAP
Tantalum
Power Resources Ltd.
MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF
Conformant
RMAP
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Conformant
RMAP
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
Conformant
RMAP
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Conformant
RMAP
Tin
Thaisarco
THAILAND
Conformant
RMAP
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
Conformant
RMAP
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
Conformant
RMAP
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Conformant
RMAP
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Conformant
RMAP
Gold
Bangalore Refinery
INDIA
On RMI Active List
 
Gold
KGHM Polska Miedz Spolka Akcyjna
POLAND
On RMI Active List
 
Gold
L'Orfebre S.A.
ANDORRA
On RMI Active List
 
Gold
Modeltech Sdn Bhd
MALAYSIA
On RMI Active List
 
Gold
Remondis Argentia B.V.
NETHERLANDS
On RMI Active List
 
Gold
SAFINA A.S.
CZECH REPUBLIC
On RMI Active List
 
Tin
Modeltech Sdn Bhd
MALAYSIA
On RMI Active List
 
Tungsten
Ganzhou Haichuang Tungsten Co., Ltd.
CHINA
On RMI Active List
 
Gold
Chugai Mining
JAPAN
Not validated
 
Gold
Daye Non-Ferrous Metals Mining Ltd.
CHINA
Not validated
 
Gold
Degussa Sonne / Mond Goldhandel GmbH
GERMANY
Not validated
 
Gold
GCC Gujrat Gold Centre Pvt. Ltd.
INDIA
Not validated
 





Metal
Smelter Name
Location of smelter
Status
Audit By
Gold
Great Wall Precious Metals Co., Ltd. of CBPM
CHINA
Not validated
 
Gold
Guangdong Jinding Gold Limited
CHINA
Not validated
 
Gold
Guoda Safina High-Tech Environmental Refinery Co., Ltd.
CHINA
Not validated
 
Gold
Hangzhou Fuchunjiang Smelting Co., Ltd.
CHINA
Not validated
 
Gold
Hunan Chenzhou Mining Co., Ltd.
CHINA
Not validated
 
Gold
Kazakhmys Smelting LLC
KAZAKHSTAN
Not validated
 
Gold
Kyshtym Copper-Electrolytic Plant ZAO
RUSSIAN FEDERATION
Not validated
 
Gold
Lingbao Gold Co., Ltd.
CHINA
Not validated
 
Gold
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
CHINA
Not validated
 
Gold
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
CHINA
Not validated
 
Gold
Navoi Mining and Metallurgical Combinat
UZBEKISTAN
Not validated
 
Gold
Pease & Curren
UNITED STATES OF AMERICA
Not validated
 
Gold
Penglai Penggang Gold Industry Co., Ltd.
CHINA
Not validated
 
Gold
Refinery of Seemine Gold Co., Ltd.
CHINA
Not validated
 
Gold
Sabin Metal Corp.
UNITED STATES OF AMERICA
Not validated
 
Gold
Sai Refinery
INDIA
Not validated
 
Gold
Shandong Tiancheng Biological Gold Industrial Co., Ltd.
CHINA
Not validated
 
Gold
State Research Institute Center for Physical Sciences and Technology
LITHUANIA
Not validated
 
Gold
Tongling Nonferrous Metals Group Co., Ltd.
CHINA
Not validated
 
Gold
TOO Tau-Ken-Altyn
KAZAKHSTAN
Not validated
 
Gold
Yunnan Copper Industry Co., Ltd.
CHINA
Not validated
 
Tin
An Vinh Joint Stock Mineral Processing Company
VIET NAM
Not validated
 
Tin
Estanho de Rondonia S.A.
BRAZIL
Not validated
 
Tin
Gejiu Zili Mining And Metallurgy Co., Ltd.
CHINA
Not validated
 
Tin
Nghe Tinh Non-Ferrous Metals Joint Stock Company
VIET NAM
Not validated
 
Tin
Super Ligas
BRAZIL
Not validated
 
Tin
Tuyen Quang Non-Ferrous Metals Joint Stock Company
VIET NAM
Not validated
 
Tungsten
Jiangxi Dayu Longxintai Tungsten Co., Ltd.
CHINA
Not validated
 
Tin
CNMC (Guangxi) PGMA Co., Ltd.
CHINA
Not validated
 
Gold
HwaSeong CJ CO., LTD.
KOREA, REPUBLIC OF
Not validated
 
Gold
Morris and Watson
NEW ZEALAND
Not validated
 
Gold
Morris and Watson Gold Coast
AUSTRALIA
Not validated
 
Gold
Samwon Metals Corp.
KOREA, REPUBLIC OF
Not validated
 
Tungsten
Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.
CHINA
Not validated
 





Metal
Smelter Name
Location of smelter
Status
Audit By
Gold
Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
TURKEY
Due Diligence Required
 
Gold
Kaloti Precious Metals
UNITED ARAB EMIRATES
Due Diligence Required
 
Gold
L'azurde Company For Jewelry
SAUDI ARABIA
Due Diligence Required
 
Gold
Abington Reldan Metals, LLC
UNITED STATES OF AMERICA
Non-Conformant
 
Tin
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC
VIET NAM
Non-Conformant
 
Tungsten
Ganzhou Yatai Tungsten Co., Ltd.
CHINA
Non-Conformant
 
Gold
Schone Edelmetaal B.V.**
NETHERLANDS
Not a Legitimate Smelter
 
Tantalum
Yichun Jin Yang Rare Metal Co., Ltd.**
CHINA
Not a Legitimate Smelter
 
Tantalum
Zhuzhou Cemented Carbide Group Co., Ltd.**
CHINA
Not a Legitimate Smelter
 
Tin
PT O.M. Indonesia**
INDONESIA
Not a Legitimate Smelter
 
Tin
VQB Mineral and Trading Group JSC*
VIET NAM
Not a Legitimate Smelter
 
Gold
So Accurate Group, Inc.*
UNITED STATES OF AMERICA
Not a Legitimate Smelter
 
Tantalum
Duoluoshan*
CHINA
Not a Legitimate Smelter
 
Tantalum
King-Tan Tantalum Industry Ltd.*
CHINA
Not a Legitimate Smelter
 
Tin
Cooperativa Metalurgica de Rondonia Ltda.*
BRAZIL
Not a Legitimate Smelter
 
Tin
PT Cipta Persada Mulia*
INDONESIA
Not a Legitimate Smelter
 
Tin
PT Justindo*
INDONESIA
Not a Legitimate Smelter
 
Tungsten
Hunan Litian Tungsten Industry Co., Ltd.****
CHINA
Non-Conformant
 
Gold
Elemetal Refining, LLC****
UNITED STATES OF AMERICA
Non-Conformant
 
Gold
Tony Goetz NV****
BELGIUM
Non-Conformant
 
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant****
RUSSIAN FEDERATION
Conformant
LBMA
Gold
Universal Precious Metals Refining Zambia****
ZAMBIA
Not validated
 
Gold
Sudan Gold Refinery****
SUDAN
Not validated
 
Gold
Fidelity Printers and Refiners Ltd.****
ZIMBABWE
Due Diligence required
 
*Previously classified as a smelter, suspended operations prior to CY2017.
**Previously classified as a smelter, suspended operations, but may have operated during CY2017.
***Previously Conformant, did not complete re-audit or corrective actions in allotted time.
****RED FLAG: reasons may include failed audit, sanctions, geographical location, publicly reported concerns, or non-DRC related legal issues. These entities will require further due diligence and action (including possible removal from supply chain) in CY2018.






Table II. The Countries of Origin for the minerals present in Plantronics products are believed to potentially include, but may not be limited to, the following. Information is from RMI smelters, news reports, industry associations, metals brokers’ reports, and USGS reports (Countries listed for 3T are reported to account for ~98% of global mined ore). Data checked for plausibility against RMI 2017 Mineral Mine Production by Country report.

Mineral
Countries of Origin
Tungsten
Democratic Republic of Congo, Burundi, Rwanda, China, Vietnam, Russia, Canada, Bolivia, Australia, Austria, Spain, Portugal, United States, DRC, Mexico, Mongolia, Uzbekistan, Uganda
Tantalum
Democratic Republic of Congo, Rwanda, Burundi, Brazil, Mozambique, China, Nigeria, Australia, Uganda, Bolivia, Colombia, Mongolia, Nigeria, Portugal, Russia, Spain, Mozambique
Tin
Bolivia, Brazil, Myanmar, China, Indonesia, Peru, Australia, Democratic Republic of Congo, Malaysia, Nigeria, Rwanda, Vietnam, Burundi, Mongolia, Niger, Portugal, Russia, Tanzania, Thailand, Uganda
Gold
China, Australia, Russia, United States, Peru, Canada, South Africa, Mexico, Uzbekistan, Ghana, Brazil, Papua New Guinea; Democratic Republic of Congo, Kazakhstan, Argentina, Tanzania, Mali, Dominican Republic, Columbia, Philippines Chile, Burkina Faso, Ivory Coast, Mongolia, Turkey, Guinea, Senegal, Togo