UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Qorvo, Inc.
(Exact name of registrant as specified in its charter)
(Exact name of registrant as specified in its charter)
Delaware | 001-36801 | 46-5288992 |
(State or Other Jurisdiction | (Commission File | (I.R.S. Employer |
of Incorporation) | Number) | Identification No.) |
7628 Thorndike Road, Greensboro, North Carolina 27409-9421 | ||
and | ||
2300 N.E. Brookwood Parkway, Hillsboro, Oregon 97124 | ||
(Address of principal executive offices) | ||
(Zip Code) | ||
Steven J. Buhaly | (503) 615-9000 | |
(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:
[X] Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.
Section 1 Conflict Minerals Disclosure 
Item 1.01 Conflict Minerals Disclosure and Report
Company Overview
On February 22, 2014, RF Micro Devices, Inc. (“RFMD”) entered into an Agreement and Plan of Merger and Reorganization (as subsequently amended on July 15, 2014, the “Merger Agreement”) with TriQuint Semiconductor, Inc. (“TriQuint”) providing for the combination of RFMD and TriQuint in a merger of equals (the “Business Combination”) under a new holding company named Qorvo, Inc. (herein referred to as the “Company, “Qorvo,” “we,” “us,” or “our”). The transactions contemplated by the Merger Agreement were consummated on January 1, 2015. During the year ended December 31, 2014, RFMD and TriQuint operated as two separate companies, but coordinated on the management of our conflict minerals programs following consummation of the Business Combination. RFMD and TriQuint worked together on the Reasonable Country of Origin Inquiry (“RCOI”) process, and in communications with suppliers and smelters. Qorvo is filing this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”) with respect to the management of conflict minerals by each of RFMD and TriQuint, now wholly-owned subsidiaries of Qorvo, during the year ended December 31, 2014.
Conflict Minerals are Necessary to the Function and Production of Qorvo Parts
Rule 13p-1 currently defines “conflict minerals” as Columbite-tantalum (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. Almost all Qorvo products intentionally contain tin, tantalum, tungsten, or gold (also known as “3TG metals”), as these metals are necessary to the functionality and production of our products. All parts do not contain all four 3TG metals, but all parts contain at least one of the 3TG metals.
Therefore, we have conducted a good faith RCOI to determine whether any of these conflict minerals originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (the “Covered Countries”), or are from recycled or scrap sources.
Reasonable Country of Origin Inquiry (RCOI)
We maintain a robust database of the composition of components and materials used to manufacture our products. Our RCOI process began with an analysis of this data to determine which of our components and materials contained a 3TG metal. We utilized the Conflict-Free Sourcing Initiative (“CFSI”) Conflict Mineral Reporting Template (“CMRT”) to engage the suppliers of those components and materials, in addition to using this tool to perform a robust survey of our supply chain. The CFSI is a leading industry program that helps manage risk by improving supply chain transparency on conflict minerals.
Through our membership and participation in the activities of the CFSI, we have access to sourcing information for those smelters in our supply chain that have been validated as compliant to the Conflict-Free Smelter Program (“CFSP”) requirements. The use of sourcing information from the CFSI is subject to the terms of the relevant Agreements of the Exchange of Confidential Information between the CFSI and the individual smelters. Those terms prohibit CFSI members from disclosing the sourcing of conflict minerals by individual smelters, even if the disclosure is necessary to meet the member’s SEC reporting obligations. The information may only be aggregated - i.e., “smelters in Qorvo’s supply chain sourced from the DRC or Covered Countries.” The terms do not allow CFSI members to state that Smelter A sources from the DRC or Covered Countries and Smelter B does not source from the DRC or Covered Countries.
The country of origin sourcing information from the CFSI can be different from the information given by suppliers in their CMRTs to Qorvo. As a result, we used the RCOI information from the CFSI as the primary source of sourcing information. If a particular smelter is not in the CFSP (and therefore we do not know its sourcing of conflict minerals), we estimate the risk of that smelter sourcing from the Covered Countries. For example, a Brazilian, Peruvian, or Indonesian tin smelter is unlikely to source from the Covered Countries, as those smelters would be very close to extremely large tin deposits in their own countries. In some cases there may be restrictions on the import of ores from other countries, when the host country has large deposits of conflict mineral ores. In a different situation, a precious metals smelter that recovers gold from anodic or cathodic slimes from copper plating in copper smelters is unlikely to be able to handle ores due to equipment and processing considerations. For those copper smelters that also have associated precious metals smelters, there is less risk of sourcing from the Covered Countries.
Conflict Minerals Disclosure
Through our RCOI process, we have become aware of at least one smelter in our suppliers’ supply chains that is sourcing from the Covered Countries for each of the 3TG metals. This is true for each of RFMD’s and TriQuint’s supply chains. Our knowledge of this smelter is obtained through our direct involvement in the CFSI and, as a condition of this participation, the identification of an individual smelter as sourcing from the Covered Countries is prohibited by confidentiality agreements. However, as of the date of this report, all smelters in our supply chain that we know or believe source from the Covered Countries are on the CFSP Conflict Free Smelter Lists, which can be accessed at http://www.conflictfreesourcing.org/conflict-free-smelter-refiner-lists/.
Because we know that some of the 3TG metals in our supply chain came from the Covered Countries (even though the relevant smelter is on the CFSP Conflict Free Smelter Lists), and because some suppliers have not identified all of the smelters in their supply chain, or we are uncertain as to the smelter’s source of the conflict minerals, we are required to exercise due diligence on the source and custody of the sourcing of these conflict minerals. We are filing a Conflict Minerals Report as Exhibit 1.01 to this Form SD to describe our due diligence process. The Conflict Minerals Report is available on our website at http://ir.qorvo.com/sec.cfm. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Item 1.02 Exhibit
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 Exhibits
Item 2.01 Exhibits
Exhibit 1.01 Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD
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 undersigned hereunto duly authorized.
Qorvo, Inc. | ||
By: | /s/ Steven J. Buhaly | |
Steven J. Buhaly | ||
Chief Financial Officer and Secretary | ||
Date: May 29, 2015
Exhibit 1.01
Qorvo, Inc.
Conflict Minerals Report
For the Year Ended December 31, 2014
Introduction
Products of Qorvo, Inc. (collectively with its wholly owned subsidiaries, TriQuint Semiconductor, Inc. (“TriQuint”) and RF Micro Devices, Inc. (“RFMD”), referred to in this report as the “Company”, “we”, “us”, or “our”) intentionally contain tin, tantalum, tungsten, and gold, as these metals are necessary to the functionality and production of our products. We have conducted a good faith Reasonable Country of Origin Inquiry (“RCOI”) to determine whether any of these conflict minerals originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (the “Covered Countries”), or are from recycled or scrap sources. As a result of the RCOI, we have become aware of at least one smelter in our suppliers’ supply chains that is sourcing from the Covered Countries. Also, our suppliers have not identified all of the smelters in their supply chains and we are uncertain as to some smelters’ sources of conflict minerals. Therefore, we are required to exercise “due diligence” on the sourcing of conflict minerals used in our products, and report on that due diligence in this Conflict Minerals Report.
Qorvo is a leading provider of core technologies and radio frequency (“RF”) solutions for mobile, infrastructure and defense and aerospace applications. We have more than 6,700 global employees dedicated to delivering solutions for everything that connects the world. Qorvo has one of the industry's broadest portfolios of RF products and core technologies, and world-class ISO9001-, ISO 14001- and ISO/TS 16949-certified manufacturing facilities. Our Richardson, Texas facility is a U.S. Department of Defense (“DoD”)-accredited ‘Trusted Source’ (Category 1A) for gallium arsenide (“GaAs”), gallium nitride (“GaN”) and bulk acoustic wave (“BAW”) technologies, products and services. We are a preferred supplier to the world’s leading companies that serve the mobile device, networks infrastructure and defense and aerospace markets. Our design and manufacturing expertise encompasses many semiconductor process technologies, which we source both internally and through external suppliers. We operate worldwide with our design, sales and manufacturing facilities located throughout Asia, Europe and North America. Our primary design and manufacturing facilities are located in North Carolina, Oregon, Texas and Florida and our primary assembly and test facilities are located in China, Costa Rica and Texas.
In this Conflict Minerals Report, we will address the following:
• | A description of due diligence measures taken. |
• | The results of and conclusion of our due diligence measures. |
• | The processing facilities used in our supply chain (i.e., “smelters”) that have not been determined to be “DRC conflict free.” |
• | Steps to be taken to improve our due diligence measures for the year ending December 31, 2015. |
We are providing this Conflict Minerals Report pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”).
Due Diligence Measures Taken
RFMD’s and TriQuint’s Conflict Mineral Programs were designed to conform to 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. Currently, this is the foremost internationally recognized due diligence framework. The OECD framework encompasses the following steps:
1. Establish strong company management systems.
2. Identify and assess risk in the supply chain.
3. Design and implement a strategy to respond to identified risks.
4. Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.
5. Report on supply chain due diligence.
As outlined in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, the internationally recognized standard on which our system is based, we support an industry initiative that audits smelters’ and refiners’ due diligence activities. That industry initiative is the Electronic Industry Citizenship Coalition (EICC) and Global e-Sustainability Initiative (GeSI) Conflict-Free Sourcing Initiative. The data on which we relied for certain statements in this Conflict Minerals Report was obtained through our membership in the Conflict-Free Sourcing Initiative (“CFSI”), using the RCOI report for members RFMD and TQNT.
1. Establish strong company management systems.
Both RFMD and TriQuint had adopted Conflict Mineral Policies. These policies are located at http://www.triquint.com/about-us/corporate-responsibility/product-compliance and http://www.rfmd.com/sites/default/files/RFMD__Conflict_Minerals_Statement.pdf. These policies are currently being integrated into a single policy for Qorvo. Our primary objectives in establishing these Conflict Mineral Policies were to:
• | inform our stakeholders (customers, suppliers, regulatory agencies, employees, and local communities) of our commitment to ensure our products were not contributing to the ongoing conflict in the conflict region; |
• | inform our stakeholders of our understanding of the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”) and how it has impacted us; |
• | inform our stakeholders that we were not banning all materials from the conflict region, as this would unfairly impact the many legitimate artisanal miners working in the region; |
• | provide tools and training to our suppliers to help them manage conflict minerals responsibly; and |
• | inform stakeholders of any pertinent sourcing information we learned as we surveyed our supply chain (i.e., whether any conflict minerals came from the conflict region). |
Both companies established cross-functional teams for conflict mineral management. Both teams regularly reported to their respective senior management.
Both companies are members of the CFSI and participate on several subteams within the CFSI. Through CFSI membership, we are able to contribute to the organization’s ongoing work in identifying and auditing due diligence practices of smelters. We participate on teams within the CFSI that:
• | determine if facilities are smelters; |
• | engage smelters in the Conflict-Free Smelter Program (“CFSP”); |
• | manage tools for CFSI members to determine the status of facilities supplied to them by their supply chains; |
• | manage the development of the Conflict Mineral Reporting Template (“CMRT”) form; and |
• | develop best practices for supply chain due diligence. |
We are also a member of IPC (an electronics industry trade group and standards making body – see www.ipc.org ) and participate in the development of standards guiding the exchange of conflict mineral data within the supply chain.
Both companies updated policies and purchasing terms and conditions to require our supply chain to support Qorvo’s efforts to ensure a conflict-free supply chain. This documentation is currently being integrated into Qorvo documentation.
The TriQuint website contained resources for suppliers to build their conflict mineral management capabilities. We provide our suppliers access to regulations, training resources, and tools to gather and analyze sourcing information from their supply chain. We also provide our supply chain a set of criteria by which we will evaluate suppliers with regard to their conflict mineral management systems. Similar information will be contained on the Qorvo website.
Both companies had established anonymous “whistleblower” webpages for employees and external parties to submit any concerns about ethical issues, or any grievances regarding our policies and practices. These policies have been combined into a single Qorvo policy (see http://ir.qorvo.com/corporate-governance.cfm and select “Whistleblower Policy” under “Policies and Procedures”).
2. Identify and assess risk in the supply chain.
We use our management system to determine which suppliers provide us with components or materials that contain tin, tantalum, tungsten, and gold. We use the CFSI CMRT to survey these suppliers, and we evaluate their responses for completeness, logic, degree of smelter identification,
and evidence of their due diligence practices. We provide feedback to our suppliers regarding the quality of their CMRT. We utilize several tools available to CFSI members to review our suppliers’ smelter lists and assess the level to which they have vetted their own supply chain relative to the originating smelter.
We use the information gathered from our participation in the CFSI to provide feedback to our suppliers and promote participation in the CFSP.
3. Design and implement a strategy to respond to identified risks.
We do not directly purchase from any smelters, nor do the majority of our suppliers. Since the electronics industry is not the most significant industry for any of the conflict minerals, except for tantalum, and we are not direct customers of smelters, we have very little influence over the smelters’ sourcing.
As part of our normal operating procedures, should we learn of smelters in our supply chain who are sourcing from the Covered Countries, and are not on the CFSP lists or active in the CFSP, we engage the direct supplier and perform further due diligence. Based on information provided by the direct supplier, including information it provides about its supply chain, our normal operating procedures are to:
1. | Continue trade with the direct supplier, while the direct supplier continues to work the risk mitigation process through its supply chain. Such steps would include communicating with and beginning engagement in the CFSP. |
2. | If the mitigation process failed and the smelter refused to engage with the CFSP, we would require the direct suppliers to identify and use alternate suppliers whose conflict mineral-processing smelters participate in the CFSP. |
For the year ended December 31, 2014, we are unaware of any smelters in our supply chain that are sourcing from the Covered Countries and are not CFSP compliant. Our Product Compliance Team reports the findings of the supply chain assessment to the Chief Financial Officer of Qorvo, who is the executive sponsor of our conflict minerals initiatives.
4. Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.
We do not have the resources or expertise to audit the smelters in our supply chain. We use the resources available from our participation in the CFSI to provide more information to our suppliers to help them get the smelters in their supply chain to participate in the CFSP. We encourage smelters in our supply chain both directly and through our direct suppliers to participate in the CFSP. We have worked with other CFSI members to translate communications to smelters into other languages, for easier communication throughout the supply chain. We intend to carry out any audit required by Rule 13p-1 of our due diligence program.
5. Report on supply chain due diligence.
We have filed this Conflict Minerals Report with the SEC, and it is available on our website at http://ir.qorvo.com/sec.cfm.
Findings
Each of RFMD and TriQuint made great progress in 2014 in identifying the sourcing of the conflict minerals in our products. Although all of the suppliers are not yet identifying all of the smelters in their supply chains, we are progressing towards this goal.
At the end of 2014, RFMD had identified 248 facilities and TriQuint had identified 177 facilities in their respective supply chains. Of these facilities, 176 were in the supply chain of both companies (meaning that RFMD had 72 facilities that were not in TriQuint’s supply chain and that TriQuint had one facility that was not in RFMD’s supply chain). Therefore, the companies combined to identify 249 total facilities in 2014.
Of these 249 facilities:
• | 242 are known smelters by the CFSI |
◦ | 157 are compliant to the CFSP |
◦ | 34 are active in the CFSP or are Tungsten Industry-Conflict Minerals Council (“TI-CMC”) members who will undergo a CFSP Audit in the near future |
◦ | 9 are in communication with CFSI and are interested in joining the CFSP |
◦ | 42 facilities require further outreach to bring them into the CFSP |
• | 7 facilities are either known to not be smelters or their status is “unknown” as a smelter. |
In addition to the foregoing data regarding the facilities of which we are aware, we have 27 suppliers that have not identified 100% of the smelters and another 17 suppliers that have not provided any sourcing information.
Unfortunately, due to these limitations in our sourcing information, we are unable to determine the origin of all of the conflict minerals contained in our products at this time (this can be considered as equivalent to stating our products are “DRC conflict undeterminable”). Although we have not identified any conflict minerals in our supply chain that have supported the ongoing conflict in the Covered Countries, we cannot affirm that our products are “DRC conflict free” at this time. This determination is made with respect to all Qorvo products.
Processing Facilities (Smelters) not known to be “DRC Conflict Free”
Since we have determined that we are unable to identify the sourcing information for all of the smelters in our supply chain, we are required to identify, if known, the facilities (i.e., smelters) that processed the conflict minerals in our products, and if known, the country of origin of those conflict minerals, and to describe the efforts to determine the mine or location of origin with the greatest possible specificity.
As a member of the CFSI, we rely on the sourcing information disclosed during the CFSP’s third party auditing process. We believe this to be the most reasonable and accurate method of determining the mines or locations of origin for conflict minerals. In addition to the smelters listed in the tables below,
our suppliers submitted other facilities that we believe are not smelters at this time. They are not listed in this Conflict Minerals Report as being “processing facilities” under Rule 13p-1. We continue to work with our supply chain to identify the legitimate smelters in our supply chain.
In the section above, we have stated that 157 smelters in our supply chain are compliant to the CFSP. These smelters are shown in Table 1 below.
Of the 85 remaining known smelters, we classify another 34 smelters as “Active” in the CFSP. They are either working with the CFSP on completing their sourcing audits, or are working to close any findings. Of these Active Smelters, 16 are TI-CMC members (see www.ti-cmc.org ). TI-CMC members have agreed to undergo a sourcing audit within 2 years of becoming a TI-CMC category A member (see http://www.ti-cmc.org/ti-cmc_framework.pdf). These 16 TI-CMC members in our supply chains have self-declared their sourcing, and none of them have declared they are sourcing from the Covered Countries. These smelters are listed in Table 2 below.
For the remaining 51 smelters, 9 more smelters are in communications with the CFSP, so we anticipate they will join the CFSP and we will learn more about their sourcing. These smelters are listed in Table 3 below.
Of the remaining 42 smelters, 17 (see Table 4 below) present a low risk of irresponsible sourcing:
• | Eight are London Bullion Market Association (“LBMA”) members in various stages of getting their Responsible Gold certificate (either setting up the audit, reviewing or closing findings of the audit, or have passed the audit but not yet listed in the CFSI list for gold smelters). The status of these smelters can be found at http://www.lbma.org.uk/Default.aspx?CCID=21993& |
FID=141296&ExcludeBoolFalse=True&ID=/refiners-gold-current.
• | Eight are either Brazilian or Indonesian tin smelters, where it is highly unlikely that they would source from the conflict region due to the large tin ore sources within their own countries. |
• | One is a Mexican gold smelter, whose gold comes from the copper plating residues in its copper processing facility, and the copper comes from its own mines in Mexico. This residue contains gold and silver, so it is processed to capture these valuable metals. It is highly unlikely that this smelter imports gold from the conflict region. |
This leaves 25 smelters (see Table 5 below) for which we do not have any sourcing information, and for which we do not have any supplemental information to provide any risk indications that these smelters are not sourcing from the conflict region in a responsible manner.
This information is presented in table format below.
Table 1. Smelters that are compliant to the CFSP (as of 19-May-2015)
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located |
Gold | Aida Chemical Industries Co., Ltd. | CID000019 | JAPAN |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | GERMANY |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | CID000058 | BRAZIL |
Gold | Argor-Heraeus SA | CID000077 | SWITZERLAND |
Gold | Asahi Pretec Corporation | CID000082 | JAPAN |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | TURKEY |
Gold | Aurubis AG | CID000113 | GERMANY |
Gold | Boliden AB | CID000157 | SWEDEN |
Gold | C. Hafner GmbH + Co. KG | CID000176 | GERMANY |
Gold | CCR Refinery – Glencore Canada Corporation | CID000185 | CANADA |
Gold | Chimet S.p.A. | CID000233 | ITALY |
Gold | Dowa | CID000401 | JAPAN |
Gold | Eco-System Recycling Co., Ltd. | CID000425 | JAPAN |
Gold | Heimerle + Meule GmbH | CID000694 | GERMANY |
Gold | Heraeus Ltd. Hong Kong | CID000707 | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | CID000711 | GERMANY |
Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | JAPAN |
Gold | Istanbul Gold Refinery | CID000814 | TURKEY |
Gold | Japan Mint | CID000823 | JAPAN |
Gold | Johnson Matthey Inc. | CID000920 | UNITED STATES |
Gold | Johnson Matthey Limited | CID000924 | CANADA |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | RUSSIAN FEDERATION |
Gold | JSC Uralelectromed | CID000929 | RUSSIAN FEDERATION |
Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | JAPAN |
Gold | Kazzinc | CID000957 | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC | CID000969 | UNITED STATES |
Gold | Kojima Chemicals Co., Ltd. | CID000981 | JAPAN |
Gold | L' azurde Company For Jewelry | CID001032 | SAUDI ARABIA |
Gold | LS-NIKKO Copper Inc. | CID001078 | KOREA, REPUBLIC OF |
Gold | Materion | CID001113 | UNITED STATES |
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located |
Gold | Matsuda Sangyo Co., Ltd. | CID001119 | JAPAN |
Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 | CHINA |
Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | SINGAPORE |
Gold | Metalor Technologies SA | CID001153 | SWITZERLAND |
Gold | Metalor USA Refining Corporation | CID001157 | UNITED STATES |
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | CID001161 | MEXICO |
Gold | Mitsubishi Materials Corporation | CID001188 | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | JAPAN |
Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | CID001220 | TURKEY |
Gold | Nihon Material Co., Ltd. | CID001259 | JAPAN |
Gold | Ohio Precious Metals, LLC | CID001322 | UNITED STATES |
Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 | JAPAN |
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | CID001326 | RUSSIAN FEDERATION |
Gold | PAMP SA | CID001352 | SWITZERLAND |
Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | INDONESIA |
Gold | PX Précinox SA | CID001498 | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd. | CID001512 | SOUTH AFRICA |
Gold | Republic Metals Corporation | CID002510 | UNITED STATES |
Gold | Royal Canadian Mint | CID001534 | CANADA |
Gold | Schone Edelmetaal | CID001573 | NETHERLANDS |
Gold | SEMPSA Joyería Platería SA | CID001585 | SPAIN |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | CHINA |
Gold | Solar Applied Materials Technology Corp. | CID001761 | TAIWAN |
Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | JAPAN |
Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | JAPAN |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CID001916 | CHINA |
Gold | Tokuriki Honten Co., Ltd. | CID001938 | JAPAN |
Gold | Umicore Brasil Ltda. | CID001977 | BRAZIL |
Gold | Umicore Precious Metals Thailand | CID002314 | THAILAND |
Gold | Umicore SA Business Unit Precious Metals Refining | CID001980 | BELGIUM |
Gold | United Precious Metal Refining, Inc. | CID001993 | UNITED STATES |
Gold | Valcambi SA | CID002003 | SWITZERLAND |
Gold | Western Australian Mint trading as The Perth Mint | CID002030 | AUSTRALIA |
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located |
Gold | Yamamoto Precious Metal Co., Ltd. | CID002100 | JAPAN |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | CHINA |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CID002243 | CHINA |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 | CHINA |
Tantalum | Conghua Tantalum and Niobium Smeltry | CID000291 | CHINA |
Tantalum | Duoluoshan | CID000410 | CHINA |
Tantalum | Exotech Inc. | CID000456 | UNITED STATES |
Tantalum | F&X Electro-Materials Ltd. | CID000460 | CHINA |
Tantalum | Global Advanced Metals Aizu | CID002558 | JAPAN |
Tantalum | Global Advanced Metals Boyertown | CID002557 | UNITED STATES |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CID000616 | CHINA |
Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | CID002501 | CHINA |
Tantalum | H.C. Starck Co., Ltd. | CID002544 | THAILAND |
Tantalum | H.C. Starck GmbH Goslar | CID002545 | GERMANY |
Tantalum | H.C. Starck GmbH Laufenburg | CID002546 | GERMANY |
Tantalum | H.C. Starck Hermsdorf GmbH | CID002547 | GERMANY |
Tantalum | H.C. Starck Inc. | CID002548 | UNITED STATES |
Tantalum | H.C. Starck Ltd. | CID002549 | JAPAN |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | CID002550 | GERMANY |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | CHINA |
Tantalum | Hi-Temp Specialty Metals, Inc. | CID000731 | UNITED STATES |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | CHINA |
Tantalum | KEMET Blue Metals | CID002539 | MEXICO |
Tantalum | KEMET Blue Powder | CID002568 | UNITED STATES |
Tantalum | King-Tan Tantalum Industry Ltd. | CID000973 | CHINA |
Tantalum | LSM Brasil S.A. | CID001076 | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 | INDIA |
Tantalum | Mineração Taboca S.A. | CID001175 | BRAZIL |
Tantalum | Mitsui Mining & Smelting | CID001192 | JAPAN |
Tantalum | Molycorp Silmet A.S. | CID001200 | ESTONIA |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | CHINA |
Tantalum | Plansee SE Liezen | CID002540 | AUSTRIA |
Tantalum | Plansee SE Reutte | CID002556 | AUSTRIA |
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located |
Tantalum | QuantumClean | CID001508 | UNITED STATES |
Tantalum | RFH Tantalum Smeltry Co., Ltd. | CID001522 | CHINA |
Tantalum | Solikamsk Magnesium Works OAO | CID001769 | RUSSIAN FEDERATION |
Tantalum | Taki Chemicals | CID001869 | JAPAN |
Tantalum | Telex Metals | CID001891 | UNITED STATES |
Tantalum | Ulba Metallurgical Plant JSC | CID001969 | KAZAKHSTAN |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CID002307 | CHINA |
Tantalum | Zhuzhou Cemented Carbide | CID002232 | CHINA |
Tin | Alpha | CID000292 | UNITED STATES |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | CID000295 | BRAZIL |
Tin | CV United Smelting | CID000315 | INDONESIA |
Tin | Dowa | CID000402 | JAPAN |
Tin | EM Vinto | CID000438 | BOLIVIA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | CHINA |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CID000244 | CHINA |
Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 | BRAZIL |
Tin | Malaysia Smelting Corporation (MSC) | CID001105 | MALAYSIA |
Tin | Melt Metais e Ligas S/A | CID002500 | BRAZIL |
Tin | Metallo-Chimique N.V. | CID002773 | BELGIUM |
Tin | Mineração Taboca S.A. | CID001173 | BRAZIL |
Tin | Minsur | CID001182 | PERU |
Tin | Mitsubishi Materials Corporation | CID001191 | JAPAN |
Tin | O.M. Manufacturing Philippines, Inc. | CID002517 | Philippines |
Tin | Operaciones Metalurgical S.A. | CID001337 | BOLIVIA |
Tin | PT Artha Cipta Langgeng | CID001399 | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | CID002503 | INDONESIA |
Tin | PT Babel Inti Perkasa | CID001402 | INDONESIA |
Tin | PT Bangka Putra Karya | CID001412 | INDONESIA |
Tin | PT Bangka Tin Industry | CID001419 | INDONESIA |
Tin | PT Belitung Industri Sejahtera | CID001421 | INDONESIA |
Tin | PT Bukit Timah | CID001428 | INDONESIA |
Tin | PT DS Jaya Abadi | CID001434 | INDONESIA |
Tin | PT Eunindo Usaha Mandiri | CID001438 | INDONESIA |
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located |
Tin | PT Mitra Stania Prima | CID001453 | INDONESIA |
Tin | PT Panca Mega Persada | CID001457 | INDONESIA |
Tin | PT Prima Timah Utama | CID001458 | INDONESIA |
Tin | PT Refined Bangka Tin | CID001460 | INDONESIA |
Tin | PT Sariwiguna Binasentosa | CID001463 | INDONESIA |
Tin | PT Stanindo Inti Perkasa | CID001468 | INDONESIA |
Tin | PT Timah (Persero) Tbk Kundur | CID001477 | INDONESIA |
Tin | PT Timah (Persero) Tbk Mentok | CID001482 | INDONESIA |
Tin | PT Tinindo Inter Nusa | CID001490 | INDONESIA |
Tin | Soft Metais Ltda. | CID001758 | BRAZIL |
Tin | Thaisarco | CID001898 | THAILAND |
Tin | White Solder Metalurgia e Mineração Ltda. | CID002036 | BRAZIL |
Tin | Yunnan Tin Group (Holding) Company Limited | CID002180 | CHINA |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CID002513 | China |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CID000499 | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | CHINA |
Tungsten | Global Tungsten & Powders Corp. | CID000568 | UNITED STATES |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CID000769 | CHINA |
Tungsten | Japan New Metals Co., Ltd. | CID000825 | JAPAN |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | CHINA |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | CHINA |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | CID002011 | VIET NAM |
Tungsten | Wolfram Bergbau und Hütten AG | CID002044 | AUSTRIA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | CHINA |
Table 2. Smelters that are active in the CFSP (as of 19-May-2015), including TI-CMC Members
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located |
Gold | Asaka Riken Co., Ltd. | CID000090 | JAPAN |
Gold | Cendres + Métaux SA | CID000189 | SWITZERLAND |
Gold | Doduco | CID000362 | GERMANY |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | RUSSIAN FEDERATION |
Gold | Torecom | CID001955 | KOREA, REPUBLIC OF |
Gold | Yokohama Metal Co., Ltd. | CID002129 | JAPAN |
Tin | China Tin Group Co., Ltd. | CID001070 | CHINA |
Tin | Fenix Metals | CID000468 | POLAND |
Tin | Metallic Resources, Inc. | CID001142 | UNITED STATES |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | VIET NAM |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | THAILAND |
Tin | PT Aries Kencana Sejahtera | CID000309 | INDONESIA |
Tin | PT BilliTin Makmur Lestari | CID001424 | INDONESIA |
Tin | PT Inti Stania Prima | CID002530 | INDONESIA |
Tin | PT Justindo | CID000307 | INDONESIA |
Tin | PT Sumber Jaya Indah | CID001471 | INDONESIA |
Tin | Rui Da Hung | CID001539 | TAIWAN |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | CHINA |
Tungsten | A.L.M.T. TUNGSTEN Corp. | CID000004 | JAPAN |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | CHINA |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CID000345 | CHINA |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CID000868 | CHINA |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | CHINA |
Tungsten | H.C. Starck GmbH | CID002541 | GERMANY |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | CID002542 | GERMANY |
Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CID000766 | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | CHINA |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | CHINA |
Tungsten | Kennametal Fallon | CID000966 | UNITED STATES |
Tungsten | Kennametal Huntsville | CID000105 | UNITED STATES |
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | CID002543 | VIET NAM |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | CID001889 | VIET NAM |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CID002095 | CHINA |
Table 3. Smelters that are in Communication with the CFSP (as of 19-May-2015)
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located |
Gold | Chugai Mining | CID000264 | JAPAN |
Gold | Do Sung Corporation | CID000359 | KOREA, REPUBLIC OF |
Gold | Guangdong Jinding Gold Limited | CID002312 | CHINA |
Gold | Hwasung CJ Co., Ltd. | CID000778 | KOREA, REPUBLIC OF |
Gold | Korea Metal Co., Ltd. | CID000988 | KOREA, REPUBLIC OF |
Gold | Samduck Precious Metals | CID001555 | KOREA, REPUBLIC OF |
Gold | SAMWON Metals Corp. | CID001562 | KOREA, REPUBLIC OF |
Tin | CNMC (Guangxi) PGMA Co., Ltd. | CID000278 | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 | CHINA |
Table 4. Smelters presenting a low risk of irresponsible sourcing (as of 21-May-2015)
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located | Sourcing Risk |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | UZBEKISTAN | LBMA Member undergoing sourcing audit |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | PHILIPPINES | Has passed LBMA Sourcing Audit |
Gold | Caridad | CID000180 | MEXICO | Copper plating residue processer |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CID000801 | CHINA | LBMA Member setting up sourcing audit |
Gold | Moscow Special Alloys Processing Plant | CID001204 | RUSSIAN FEDERATION | LBMA Member undergoing sourcing audit |
Gold | Navoi Mining and Metallurgical Combinat | CID001236 | UZBEKISTAN | LBMA Member undergoing sourcing audit |
Gold | OJSC Kolyma Refinery | CID001328 | RUSSIAN FEDERATION | LBMA Member undergoing sourcing audit |
Gold | OJSC Novosibirsk Refinery | CID000493 | RUSSIAN FEDERATION | LBMA Member undergoing sourcing audit |
Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | RUSSIAN FEDERATION | LBMA Member undergoing sourcing audit |
Tin | CV Gita Pesona | CID000306 | INDONESIA | Indonesian Tin |
Tin | CV Serumpun Sebalai | CID000313 | INDONESIA | Indonesian Tin |
Tin | Estanho de Rondônia S.A. | CID000448 | BRAZIL | Brazilian Tin |
Tin | PT Alam Lestari Kencana | CID001393 | INDONESIA | Indonesian Tin |
Tin | PT Fang Di MulTindo | CID001442 | INDONESIA | Indonesian Tin |
Tin | PT Karimun Mining | CID001448 | INDONESIA | Indonesian Tin |
Tin | PT Seirama Tin Investment | CID001466 | INDONESIA | Indonesian Tin |
Tin | PT Supra Sukses Trinusa | CID001476 | INDONESIA | Indonesian Tin |
Table 5. Remaining Smelters in RFMD and TriQuint Supply Chains
Metal | Standard Smelter Name | Smelter ID | Country where smelter is located |
Gold | Advanced Chemical Company | CID000015 | UNITED STATES |
Gold | Bauer Walser AG | CID000141 | GERMANY |
Gold | Daejin Indus Co., Ltd. | CID000328 | KOREA, REPUBLIC OF |
Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 | CHINA |
Gold | Faggi Enrico S.p.A. | CID002355 | ITALY |
Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CID000522 | CHINA |
Gold | Geib Refining Corporation | CID002459 | UNITED STATES |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 | CHINA |
Gold | Hunan Chenzhou Mining Group Co., Ltd. | CID000767 | CHINA |
Gold | Jiangxi Copper Company Limited | CID000855 | CHINA |
Gold | Kyrgyzaltyn JSC | CID001029 | KYRGYZSTAN |
Gold | Lingbao Gold Company Limited | CID001056 | CHINA |
Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 | CHINA |
Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 | CHINA |
Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 | CHINA |
Gold | Sabin Metal Corp. | CID001546 | UNITED STATES |
Gold | So Accurate Group, Inc. | CID001754 | UNITED STATES |
Gold | The Great Wall Gold and Silver Refinery of China | CID001909 | CHINA |
Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 | CHINA |
Gold | Yunnan Copper Industry Co., Ltd. | CID000197 | CHINA |
Tin | Feinhütte Halsbrücke GmbH | CID000466 | GERMANY |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd. | CID000760 | CHINA |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | CID001063 | CHINA |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 | CHINA |
Calendar Year 2014 Due Diligence Planned Improvements
Our planned improvements and results within the OECD Framework for the year ended December 31, 2014 were:
1. Establish strong company management systems.
Planned improvement: Continue to build supplier capabilities to respond to our requests for information and report on their supply chain. Maintain website for supplier information. Keep tools updated to allow use of updated versions of the CMRT [TriQuint].
We are developing systems to track not only in-scope supplier responses, but also smelter status statistics both at the level of each individual supplier and at an overall company level [RFMD].
We have set goals to obtain a 100% response rate from all identified in-scope suppliers, including continued supplier engagement and training [RFMD].
Results: RFMD and TriQuint continued to work with their suppliers and customers to help them understand and meet conflict mineral requirements. Tools on TriQuint’s website were updated several times throughout the year to enable suppliers to continue using them for conflict mineral management. RFMD and TriQuint developed tools to quickly review a supplier’s CMRT and provide customized responses to that supplier regarding their due diligence and smelters. As discussed in the Findings section of this Conflict Minerals Report, we have not yet identified 100% of the smelters from 100% of our suppliers of 3TG metals. We have made significant progress towards this goal, but we still have 17 suppliers who have not provided us with a CMRT.
2. Identify and assess risk in the supply chain.
Planned improvement: Ensure appropriate reviews of all new chemicals, materials and components, to determine which contain conflict minerals and gather the appropriate CMRTs from suppliers of these new materials [TriQuint].
Results: RFMD and TriQuint continued to review new materials and components for 3TG metal content and worked to gather CMRTs from those suppliers whose materials and components contained 3TG metals.
Planned improvement: We are working with our in-scope suppliers with large smelter lists to narrow the scope of products covered by the CMRT provided to us to be limited only to those materials, parts, components or manufactured products supplied [RFMD].
Results: RFMD and TriQuint worked with certain suppliers to gather “Product-specific” CMRTs that resulted in higher levels of smelter identification and removed many “problem” facilities (whether legitimate smelters or not) from our Smelter List. RFMD and TriQuint also provided “Product-specific” CMRTs to our customers to help them.
Planned improvement: Gather conflict mineral sourcing information on the CAP Wireless products for reporting in May 2015.
Results: We did not meet expectations on this goal. Production of several of the CAP Wireless products (now known as “Spatium” products) underwent significant changes after the business combination of RFMD and TriQuint, and it was decided to wait until production decisions were finalized before working on this improvement.
Planned improvement: Continue to participate in the EICC and CFSI, helping the industry to identify new smelters and promote the smelters’ inclusion in the CFSP [TriQuint].
We are continuing our efforts to directly contact smelters and refiners identified in our supply chain survey process that have not received a “DRC conflict free” designation and request their participation in the CFSP or other independent third party audit program in order for them to obtain such a “DRC conflict free” designation [RFMD].
Results: Both RFMD and TriQuint were active participants in the CFSI teams (as discussed above in the “Due Diligence Measures Taken” section). RFMD and TriQuint sent out several emails either directly to smelters or to our supply chain partners, urging participation in the CFSP. RFMD and TriQuint personnel served on Smelter Engagement Teams for Tungsten and for European-Russian smelter engagement.
Planned improvement: We are developing and implementing a strategy to obtain upstream information by way of bypassing the direct suppliers within our supply chain who are not subject to the Dodd-Frank Act and therefore would not be required to conduct supply chain due diligence on any further downstream suppliers or comply with the reporting obligations pursuant to the Rule [RFMD].
Results: It is a common industry practice to purchase materials and components from a “distributor” who is not subject to the Dodd-Frank Act requirements. It has been challenging to obtain this data. However, of the 15 distributors identified in RFMD’s supply chain, the original manufacturers for those components and materials were identified and CMRTs were requested and received from most of those manufacturers.
3. Design and implement a strategy to respond to identified risks.
Planned improvement: Continue to monitor smelter/supplier sourcing. If any Covered Country sourcing is identified, and the smelter is not a CFSP-compliant smelter, initiate our risk management plan [TriQuint].
We are immediately engaging with our direct suppliers found to be supplying us with 3TG metals from sources that support conflict in the DRC or any adjoining country to establish an alternative source of 3TG metals that does not support such conflict [RFMD].
Results: At this time, we know of no smelters sourcing from a Covered Country that is not a CFSP-compliant smelter. We continue to monitor this situation.
4. Carry out independent third-party audit of supply chain due diligence at identified points in the supply chain.
Planned improvement: Continue to work with the EICC and CFSI to encourage/pressure smelters to join the CFSP, which requires audits, and to conduct audits required by Rule 13p-1 [TriQuint].
Results: Both RFMD and TriQuint were active participants in the CFSI teams (as discussed above in the “Due Diligence Measures Taken” section). RFMD and TriQuint sent out several emails either directly to smelters or to our supply chain partners, urging participation in the CFSP. RFMD and TriQuint personnel served on Smelter Engagement Teams for Tungsten and for European-Russian smelter engagement.
5. Report on supply chain due diligence.
Planned improvement: Update information on TriQuint external website to inform stakeholders of TriQuint progress in identifying conflict mineral sourcing. File appropriate reports with the Securities and Exchange Commission in May 2015 [TriQuint].
Results: Due to the business combination of RFMD and TriQuint, Qorvo will file the Conflict Minerals Report in May 2015.
Calendar Year 2015 Due Diligence Planned Improvements
For the year ending December 31, 2015, we plan to:
• | Continue to engage in the activities described above in “Due Diligence Measures Taken.” |
• | Continue contacting smelters and refiners identified in Tables 3, 4, and 5 above that have not yet received a “DRC conflict free” designation and request their participation in the CFSP or other independent third party audit program in order for them to obtain such a “DRC conflict free” designation. |
• | Continue to work with those suppliers who have either not provided smelter information, or have provided incomplete information, or have identified facilities that are not smelters in their CMRT and drive them to 100% identification of the smelters in their supply chains. |
Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements, including statements regarding our due diligence planned improvements, and other statements preceded by terminology such as “believes,” “continue,” “could,” “estimates,” “expects,” “goal,” “hope,” “intends,” “may,” “plans,” “potential,” “predicts,” “projects,” “reasonably,” “should,” “thinks,” “will” or the negative of these terms or other comparable terminology, and include, among others, our planned improvements. These statements are only predictions or our current intentions. We do not guarantee future activities, performance or achievements, which could be affected by, among other things, changes in Rule 13p-1, interpretations of Rule 13p-1, international due diligence frameworks, law, our internal allocation of resources or emphasis, customer demands or expectations, and the cooperation of suppliers. We do not intend to update any of the forward-looking statements after the date of this Conflict Minerals Report. These forward-looking statements are made in reliance upon the safe harbor provision of The Private Securities Litigation Reform Act of 1995.