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)
Delaware | 001-36801 | 46-5288992 |
(State or other jurisdiction of incorporation) | (Commission File Number) | I.R.S. Employer Identification No.) |
7628 Thorndike Road Greensboro, North Carolina 27409-9421 | |
(Address of principal executive offices) (Zip Code) | |
Mark J. Murphy | (336) 664-1233 |
(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, 2018.
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934, as amended, Qorvo, Inc. (“Qorvo”) has filed a Conflict Minerals Report as Exhibit 1.01 to this Specialized Disclosure Report on Form SD. Both reports are publicly available on Qorvo’s website at https://ir.qorvo.com/financial-information/sec-filings.
The content of any website referred to in this report is included for general information only, and is not incorporated by reference in this report.
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 No. | Description |
1.01 | |
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
Qorvo, Inc.
By: | /s/ Mark J. Murphy | Date: May 24, 2019 | |
Mark J. Murphy | |||
Chief Financial Officer | |||
Exhibit 1.01
QORVO, INC.
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2018
INTRODUCTION
This Conflict Minerals Report (“CMR”) for Qorvo, Inc. (referred to collectively with its wholly owned subsidiaries in this report as the “Company”, “Qorvo”, “we”, “us”, or “our”) is filed with the Securities and Exchange Commission (“SEC”) as an exhibit to Qorvo’s Specialized Disclosure Report on Form SD for the year ended December 31, 2018, pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). Rule 13p-1 imposes certain due diligence and reporting obligations on SEC registrants that manufacture products, or contract to have products manufactured, that contain “conflict minerals” necessary to the functionality or production of those products. “Conflict Minerals”, as defined by the SEC, include columbite-tantalite (coltan), cassiterite, wolframite, gold, and their derivatives, which are limited to tantalum, tin and tungsten (also referred to as “3TG”).
If any conflict minerals are necessary to the functionality or production of at least one of the products manufactured or contracted to have manufactured by the SEC registrant, the company must conduct a good faith Reasonable Country of Origin Inquiry (“RCOI”) that is reasonably designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo (the “DRC”) or an adjoining country (collectively, the “Covered Countries”), or are from recycled or scrap sources. If based on the RCOI, the registrant knows or has reason to believe that any of the conflict minerals may have originated in a Covered Country and has reason to believe that they may not be from recycled or scrap sources, the registrant must exercise due diligence on the source and chain of custody of the 3TG to determine if the conflict minerals used directly or indirectly financed or benefited armed groups in the Covered Countries. Products that do not directly or indirectly finance or benefit armed groups in the Covered Countries are considered to be “DRC conflict-free.”
PRODUCT DESCRIPTION
Qorvo (Nasdaq: QRVO) makes a better world possible by providing innovative Radio Frequency (“RF”) solutions at the center of connectivity. We combine product and technology leadership, systems-level expertise and global manufacturing scale to quickly solve our customers’ most complex technical challenges. Qorvo serves diverse high-growth segments of large global markets, including advanced wireless devices, wired and wireless networks and defense radar and communications. We also leverage unique competitive strengths to advance 5G networks, cloud computing, the Internet of Things (“IoT”), and other emerging applications that expand the global framework interconnecting people, places and things.
Almost all Qorvo products intentionally contain at least one of the 3TG metals, as these metals are necessary to the functionality and production of our products. For the year ended December 31, 2018 we identified the below listed products, which we manufactured or contracted to have manufactured, that may contain conflict minerals necessary to their functionality or production.
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We design, develop, manufacture and market our products to U.S. and international original equipment manufacturers and original design manufacturers in two operating segments: Mobile Products (“MP”) and Infrastructure and Defense Products (“IDP”).
Mobile Products
MP is a global supplier of cellular RF and Wi-Fi solutions for a variety of mobile devices, including smartphones, wearables, laptops, tablets and cellular-based applications for the IoT.
Infrastructure and Defense Products
IDP is a global supplier of RF and system-on-a-chip solutions for cellular base stations and other wireless communications infrastructure, defense, smart home, automotive and other IoT applications.
OVERVIEW
Although most of our products contain conflict minerals, Qorvo does not directly source 3TG from mines or “mineral processors” (herein referred to as “smelters and refiners” or “SORs”). Instead, we source components and materials from suppliers, who source their components and materials from sub-tier suppliers. The Company is far removed from the SORs in our supply chain, and is therefore considered a “downstream company”, as described by the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”). Due to our position in the supply chain, we rely on our “relevant suppliers” – suppliers that supply Qorvo with components and/or materials containing 3TG – to provide information on the conflict minerals necessary to the functionality and production of our products. Relevant suppliers are requested to assist in our RCOI and due diligence efforts, including the identification of the smelters and refiners for the conflict minerals used in the products supplied to Qorvo.
In accordance with Rule 13p-1, Qorvo conducted a good faith RCOI to determine if any of the conflict minerals used in our products originated in the Covered Countries, or from recycled or scrap sources. As a result of this effort, we determined that some of the 3TG used in our products may have originated in the Covered Countries. Therefore, we have exercised due diligence to determine the source and chain of custody of these conflict minerals, as described in this CMR.
Upon the exercise of our due diligence – which is subject to and limited by our ability to obtain reliable information for the conflict minerals used in our products – we have not identified any occurrence where our 3TG sourcing has directly or indirectly financed or benefited armed groups in the Covered Countries.
REASONABLE COUNTRY OF ORIGIN INQUIRY
Qorvo maintains a robust database cataloguing the composition of components and materials used to manufacture our products. For the year ended December 31, 2018, Qorvo’s RCOI process began with an analysis of this data to determine which of our components and materials contained a 3TG metal. Qorvo’s RCOI also included a process for identifying our 3TG relevant suppliers and surveying those suppliers with the use of the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Relevant suppliers were requested to identify the smelters and refiners that processed the 3TG used in the components and/or materials supplied to Qorvo. We evaluated supplier responses for completeness, logic and degree of supply chain risk, and contacted those suppliers whose CMRTs we identified to contain possible risks, and/or incomplete or potentially inaccurate data. We also reviewed the SOR data provided by our suppliers against the lists of processing facilities that have been validated by a third-party audit program such as the RMI Responsible Minerals Assurance Process (“RMAP”), London Bullion Market Association (“LBMA”) Responsible Gold
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Program, or the Responsible Jewellery Council (“RJC”) Chain-of-Custody Certification. We documented country of origin information for the identified SORs as provided by sources including relevant supplier CMRT responses, the RMI’s RCOI report for member companies, and publicly available sources, if we determined such publicly available information to be reliable.
DUE DILIGENCE DESIGN
Qorvo’s conflict minerals program was designed to conform to the five-step framework of the OECD Guidance, as it relates to our position in the supply chain as a “downstream company”. In accordance with this framework, Qorvo’s conflict minerals program includes the design components listed below. Related process and procedures are also documented in our internal Document Control Center.
(1) Establish Strong Company Management Systems
Conflict Minerals Policy
Qorvo has adopted and continues to maintain a policy for the responsible sourcing of conflict minerals. This policy is made publicly available on our external website, and is regularly reviewed and updated as determined necessary.
The content of any website referred to in this report is included for general information only, and is not incorporated by reference in this report.
Internal Management Team
The Company operates an internal “Product Compliance” team, which includes a specialist who provides conflict minerals expertise, led by Qorvo’s Global Sourcing organization. The team regularly reports on the status of the conflict minerals program to senior management, including the Vice President of Global Operations, the Senior Director of Global Sourcing, and the Chief Financial Officer.
Supply Chain System of Controls and Transparency
Qorvo has developed a supply chain system of controls and transparency through the engagement of direct suppliers and requesting relevant 3TG sourcing information. The goal of this system is to collect the necessary information from suppliers to identify the SORs used in Qorvo’s supply chain and to obtain the information necessary to meet legal and customer reporting requirements.
Our relevant suppliers provide us with information on the source of the 3TG used in their products with the use of tools such as the CMRT. Qorvo employs a third-party database to assess supplier responses for completeness, logic and degree of supply chain risk. We then investigate each identified issue and engage with those suppliers to address concerns with meeting Qorvo’s conflict mineral requirements.
Supplier Engagement
Qorvo regularly communicates elements of its conflict minerals program to suppliers through different channels. This communication includes policies, expectations, requirements and results of our CMRT reviews. We employ a third-party database to assess supplier responses for completeness, logic and degree of supply chain risk. We investigate each identified issue and engage with those suppliers to address concerns with meeting Qorvo’s conflict mineral requirements.
Specific requirements related to conflict minerals are also communicated in Qorvo’s standard Purchase Order Terms and Conditions so that current and future suppliers are made aware of our policies and requirements for conflict minerals. These terms are available on our website at: https://www.qorvo.com/support/supplier-resources/.
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Grievance Mechanism
Qorvo’s whistleblower policy expresses our commitment to provide open and effective channels of communication for employees and third parties who may be impacted by our operations. Our Ethicspoint website allows employees and others to anonymously submit concerns regarding ethical issues, or any grievance related to our policies and practices. Our whistleblower policy and Ethicspoint website can be accessed at:
For any conflict minerals related grievance, Qorvo employees and external parties may also submit concerns or information to ConflictMinerals@qorvo.com. The Conflict Minerals Specialist will route the grievance to our Compliance Officer at ComplianceOfficer@qorvo.com for further investigation. In addition, Qorvo monitors the RMI’s Grievance Mechanism Report and discussions for any issue that may be applicable to the Company:
(2) | Identify and Assess Risks in the Supply Chain |
Identify 3TG Mineral Sources
The Product Compliance team regularly reviews the Qorvo Approved Supplier Lists to identify suppliers that may provide components and/or materials that contain conflict minerals. Using the industry-standard CMRT, we conduct bi-annual surveys or “CMRT campaigns” of these suppliers to identify relevant 3TG sourcing information, including the smelters and refiners that processed the conflict minerals used in Qorvo products. We evaluate supplier responses and contact those suppliers whose CMRTs we identify as containing possible risks and/or incomplete or potentially inaccurate data.
For the 2018 reporting year, Qorvo conducted a survey of 119 relevant suppliers. 100% of these suppliers provided a response to our survey requests, and 98% reported that they identified all of the SORs used in their supply chains.
Identify and Assess Supply Chain Risks
Our risk assessment is designed to identify potential risks in the supply chain, including suppliers and SORs that do not meet our conflict mineral requirements. Possible risks may include, but are not limited to the following:
• | Supplier is unresponsive to Qorvo conflict mineral requests and/or does not address identified concerns. |
• | Supplier has not received conflict minerals data from all relevant sub-tier suppliers. |
• | Supplier’s 3TG sourcing contributes to armed conflict in the Covered Countries. |
• | Supplier has reported one or more SOR that has not been validated by a third-party audit program. |
Qorvo employs a third-party database to analyze supplier CMRT data based on criteria established by Qorvo in collaboration with the third-party. Based on this analysis and review by the Conflict Minerals Specialist, suppliers receive an overall risk rating.
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Assess SOR Due Diligence
We review the SOR data provided by our suppliers against the list of processing facilities that have received a “conflict-free” designation from an independent third-party audit program (herein referred to as “conformant” SORs). We then compare those conformant SORs to the RMI’s sourcing data, which is provided as a benefit of our RMI membership, to conduct our RCOI.
(3) | Design and Implement a Strategy to Respond to Identified Risks |
Adopt a Risk Management Plan
We have established a risk management plan that includes due diligence reviews of relevant suppliers and SORs. We utilize several tools available to RMI members to review the SORs reported by our suppliers and assess the quality of the responses in their CMRTs.
Qorvo Supplier Specification (SPE-001288)
Qorvo has developed a specification to communicate to suppliers our expectations for the responsible sourcing of conflict minerals. The specification requires relevant 3TG suppliers to:
• | Establish a policy to outline their commitment to responsible 3TG sourcing; |
• | Survey their supply chain using the CMRT to identify the SORs used to process the 3TG in the components and/or materials supplied to Qorvo; |
• | Identify 100% of their suppliers and associated SORs from which those components and/or materials are sourced; |
• | Confirm the 3TG SORs used in their supply chain to Qorvo are validated by a third-party audit program; |
• | Respond to all Qorvo requests for further information regarding their CMRT submissions and/or reported SORs; and |
• | Implement the above referenced requirements with their sub-tier suppliers. |
Implement a Risk Management Plan
Qorvo has developed a risk mitigation plan to help bring suppliers into compliance with our conflict minerals requirements. Mitigation efforts may include, but are not limited to: communicating the risk and mitigation requirements to the supplier; providing due diligence guidance and/or training to the supplier; continuing trade with the supplier while the supplier works through the mitigation process with their supply chain; contacting non-validated SORs (directly/indirectly) to encourage RMAP participation; monitoring the supplier and/or SOR to measure their progress with meeting Qorvo’s requirements; or disengaging with the supplier and/or SOR if the mitigation process fails.
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Monitor and Record Progress
Qorvo maintains a conflict minerals risk management tool to monitor and track potential risks related to 3TG sourcing. This tool is intended to: record potential risks identified in a supplier’s CMRT submission; track mitigation efforts performed on the potential risks; and maintain a current understanding of risks and their impacts on Qorvo.
Report to Senior Management
We provide progress updates to senior management summarizing the data received from our bi-annual CMRT campaigns, and if necessary, the status of any ongoing mitigation efforts.
(4) | Support Independent Third-Party Audits of SOR Due Diligence |
Supporting Recognized Audit Programs
Qorvo does not have the resources or the expertise to audit the SORs in our supply chain. Instead, we rely on the due diligence conducted by programs such as the RMI, LBMA and RJC to coordinate third-party audits of global 3TG processors and validate their responsible sourcing practices.
We support the development and implementation of due diligence practices through our membership and participation in the RMI. Through this membership, we are able to contribute to the organization’s ongoing work in identifying and auditing the sourcing practices of SORs. Qorvo leads the RMI’s Smelter Data Management team, which manages research data gathered and reported on 3TG processing facilities. We also participate on teams that determine if facilities meet the definition of a smelter or refiner, encourage SORs to participate in the RMAP, manage the development of the CMRT form, and develop best practices for supply chain due diligence.
The Data on which we relied for certain statements in the Conflict Minerals Report was obtained through our membership in the RMI, using the RCOI report for Qorvo (Member Code: QRVO).
(5) | Report on Supply Chain Due Diligence |
Publicly Report on Due Diligence Activities
Qorvo’s Conflict Minerals Policy and additional information related to Qorvo’s conflict minerals program are publicly available on our website at: http://www.qorvo.com/about-us/corporate-social-responsibility/product-compliance.
In addition, our RCOI and due diligence practices are communicated through our Form SD and CMR, which are filed annually with the SEC. These reports are available at: https://ir.qorvo.com/financial-information/sec-filings.
DUE DILIGENCE MEASURES PERFORMED
For the year ended December 31, 2018, Qorvo performed the following due diligence measures on the source of the 3TG we have reason to believe may have originated in the Covered Countries:
• | Communicated our conflict minerals policy, expectations and requirements to relevant suppliers. |
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• | Conducted a bi-annual CMRT campaign of the suppliers we identified may be providing Qorvo with materials and/or components containing 3TG to determine whether any of these minerals originated in the Covered Countries. |
• | Maintained a third-party database to track communications with relevant suppliers, analyze the CMRTs provided by suppliers, aggregate supplier CMRT data for Qorvo reporting, and follow-up with suppliers whose CMRTs we identified to contain possible risks and/or incomplete or potentially inaccurate data. |
• | Provided resources to assist suppliers in complying with Qorvo’s 3TG requirements, including program notification letters; specific SOR information; and CMRT review criteria. |
• | Evaluated supplier CMRT submissions for completeness, logic and degree of supply chain risk. |
• | Reviewed supplier due diligence activities, such as whether the suppliers have a conflict minerals policy, require their direct suppliers to be “conflict-free” and have due diligence review processes in place. |
• | Compared SORs identified by relevant suppliers against the lists of SORs validated as conformant to a responsible sourcing program (i.e., RMAP, LBMA, RJC). |
• | Compared the conformant SORs reported by our suppliers to the RMI’s sourcing data. |
• | Contacted those suppliers whose CMRTs contained incomplete or potentially inaccurate information, requesting additional clarification to ensure accuracy of the information reported. |
• | Monitored and tracked relevant suppliers and SORs we identified as not meeting Qorvo requirements to determine their progress in becoming compliant. |
• | Performed mitigation efforts with relevant suppliers we identified as not meeting Qorvo requirements to bring them into compliance. |
• | Reported on the status of Qorvo’s conflict minerals program to senior management. |
• | Added conflict minerals to Qorvo’s internal Supplier Scorecard mechanism. |
• | Updated conflict mineral language in Qorvo’s standard terms and conditions. |
• | Updated the supplier requirements in supplier specification SPE-001288. |
• | Updated the conflict minerals risk management procedure and tracking tool. |
• | Contributed to the implementation of the RMAP through our membership and participation in the RMI. |
• | Supported various RMI activities through our participation on various RMI sub-teams. |
• | Disclosed information regarding our conflict mineral due diligence efforts through our Form SD and CMR, which will be made available on our website at: https://ir.qorvo.com/financial-information/sec-filings. |
• | Obtained an independent private sector audit, set forth as Exhibit A to this report. |
DUE DILIGENCE RESULTS
Inherent Limitation on Due Diligence Measures Taken
The due diligence measures listed above can only provide reasonable, not absolute, assurance regarding the origin of the conflict minerals used in our products. Our due diligence process is based on obtaining the accurate 3TG information from our relevant suppliers and those suppliers obtaining similar information from their supply
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chains to identify the original sources of the 3TG used in our products. As we do not directly purchase from any SORs – nor do the majority of our suppliers – we have very little influence over SOR sourcing. We rely, to a large extent, on the information provided by independent third-party audit programs. Such sources of information may contain incomplete or inaccurate data, and may be subject to fraud.
Smelter and Refiner Due Diligence Results
Qorvo has made a reasonable and good faith effort to collect and analyze information on the 3TG smelters and refiners reported by our relevant suppliers for the 2018 reporting year. As a result, Qorvo identified 252 potential SORs that may be used in our supply chain. We conducted due diligence on these reported facilities, including whether they are actual smelters or refiners (according to the definitions used by the RMI); whether they are currently operational; and whether they are conformant to a third-party audit program such as the RMAP, LBMA or RJC.
The Figures below provide an overview of the potential SORs identified in Qorvo’s supply chain by RMAP status. Figure 1 summarizes the reported SORs by RMAP participation status and reporting year; and Figure 2 summarizes the SORs reported in 2018 by RMAP participation status and 3TG.
Figure 1: Identified SOR Participation Status by Reporting Year
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Figure 2: Identified SOR Participation Status by 3TG for 2018
Table 1 summarizes the RMAP participation Status of the 252 potential SORs in Qorvo’s supply chain for the 2018 reporting year. This table indicates the number of facilities that:
• | Have been validated as conformant to the RMAP (“Conformant”). |
• | Are participating in the RMAP and have committed to undergo a third-party audit (“Active”). |
• | Were determined to be non-operational by the RMI during the 2018 reporting year (“Non-Eligible”). |
Table 1: Participation Status of Identified SORs for the 2018 Reporting Period
Conflict Mineral | Conformant | Active | Non-Eligible |
Tin | 69 | 1 | 4 |
Tantalum | 39 | 0 | 0 |
Tungsten | 38 | 0 | 2 |
Gold | 98 | 0 | 1 |
Total | 244 | 1 | 7 |
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In addition to the foregoing data regarding the 3TG processing facilities of which we are aware, we have two suppliers that have not yet identified all of the SORs in their supply chains. Due to these limitations in our sourcing information, we were unable to determine the origin of all the conflict minerals used in our products during the reporting period. However, as of the date of this report, all SORs that we know or have reason to believe may source from the Covered Countries have been validated as conformant to the RMAP.
PROCESSING FACILITIES (“SORs”) IDENTIFIED FOR THE 2018 REPORTING YEAR
As a member of the RMI, we utilize the sourcing information disclosed during the RMAP’s third-party auditing process to determine the mines or locations of origin for the conflict minerals that may be used in our products. We believe this to be the most reasonable and accurate method for validating the sourcing practices of 3TG smelters and refiners. Of the 252 potential SORs submitted by our suppliers, 7 are not eligible for the RMAP at this time. These facilities are not included in this report as “processing facilities” and are not included in Table 2 below.
Table 2: Identified SORs in Qorvo’s Supply Chain as of March 5, 2018
Mineral | Smelter Name | Smelter ID | Smelter Location |
Tantalum | Asaka Riken Co., Ltd.* | CID000092 | JAPAN |
Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | CID000211 | CHINA |
Tantalum | D Block Metals, LLC* | CID002504 | UNITED STATES OF AMERICA |
Tantalum | Exotech Inc.* | CID000456 | UNITED STATES OF AMERICA |
Tantalum | F&X Electro-Materials Ltd.* | CID000460 | CHINA |
Tantalum | FIR Metals & Resource Ltd.* | CID002505 | CHINA |
Tantalum | Global Advanced Metals Aizu* | CID002558 | JAPAN |
Tantalum | Global Advanced Metals Boyertown* | CID002557 | UNITED STATES OF AMERICA |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd.* | CID000291 | CHINA |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd.* | CID000616 | CHINA |
Tantalum | H.C. Starck Co., Ltd.* | CID002544 | THAILAND |
Tantalum | H.C. Starck Hermsdorf GmbH* | CID002547 | GERMANY |
Tantalum | H.C. Starck Inc.* | CID002548 | UNITED STATES OF AMERICA |
Tantalum | H.C. Starck Ltd.* | CID002549 | JAPAN |
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Tantalum | H.C. Starck Smelting GmbH & Co. KG* | CID002550 | GERMANY |
Tantalum | H.C. Starck Tantalum and Niobium GmbH* | CID002545 | GERMANY |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | CID002492 | CHINA |
Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | CID002512 | CHINA |
Tantalum | Jiangxi Tuohong New Raw Material* | CID002842 | CHINA |
Tantalum | Jiujiang Janny New Material Co., Ltd.* | CID003191 | CHINA |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | CID000914 | CHINA |
Tantalum | Jiujiang Tanbre Co., Ltd.* | CID000917 | CHINA |
Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* | CID002506 | CHINA |
Tantalum | KEMET Blue Metals* | CID002539 | MEXICO |
Tantalum | KEMET Blue Powder* | CID002568 | UNITED STATES OF AMERICA |
Tantalum | LSM Brasil S.A.* | CID001076 | BRAZIL |
Tantalum | Metallurgical Products India Pvt., Ltd.* | CID001163 | INDIA |
Tantalum | Mineracao Taboca S.A.* | CID001175 | BRAZIL |
Tantalum | Mitsui Mining and Smelting Co., Ltd.* | CID001192 | JAPAN |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd.* | CID001277 | CHINA |
Tantalum | NPM Silmet AS* | CID001200 | ESTONIA |
Tantalum | QuantumClean* | CID001508 | UNITED STATES OF AMERICA |
Tantalum | Resind Industria e Comercio Ltda.* | CID002707 | BRAZIL |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.* | CID001522 | CHINA |
Tantalum | Solikamsk Magnesium Works OAO* | CID001769 | RUSSIAN FEDERATION |
Tantalum | Taki Chemical Co., Ltd.* | CID001869 | JAPAN |
Tantalum | Telex Metals* | CID001891 | UNITED STATES OF AMERICA |
Tantalum | Ulba Metallurgical Plant JSC* | CID001969 | KAZAKHSTAN |
Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | CID002508 | CHINA |
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Tin | Alpha* | CID000292 | UNITED STATES OF AMERICA |
Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | CID000228 | CHINA |
Tin | Chifeng Dajingzi Tin Industry Co., Ltd.* | CID003190 | CHINA |
Tin | China Tin Group Co., Ltd.* | CID001070 | CHINA |
Tin | CV Ayi Jaya* | CID002570 | INDONESIA |
Tin | CV Dua Sekawan* | CID002592 | INDONESIA |
Tin | CV Gita Pesona* | CID000306 | INDONESIA |
Tin | CV United Smelting* | CID000315 | INDONESIA |
Tin | CV Venus Inti Perkasa* | CID002455 | INDONESIA |
Tin | Dowa* | CID000402 | JAPAN |
Tin | EM Vinto* | CID000438 | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | Fenix Metals* | CID000468 | POLAND |
Tin | Gejiu Fengming Metallurgy Chemical Plant* | CID002848 | CHINA |
Tin | Gejiu Kai Meng Industry and Trade LLC* | CID000942 | CHINA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CID000538 | CHINA |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.* | CID001908 | CHINA |
Tin | Gejiu Zili Mining And Metallurgy Co., Ltd.** | CID000555 | CHINA |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* | CID003116 | CHINA |
Tin | Guanyang Guida Nonferrous Metal Smelting Plant* | CID002849 | CHINA |
Tin | HuiChang Hill Tin Industry Co., Ltd.* | CID002844 | CHINA |
Tin | Huichang Jinshunda Tin Co., Ltd.* | CID000760 | CHINA |
Tin | Jiangxi New Nanshan Technology Ltd.* | CID001231 | 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 |
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Tin | Metallic Resources, Inc.* | CID001142 | UNITED STATES OF AMERICA |
Tin | Metallo Belgium N.V.* | CID002773 | BELGIUM |
Tin | Metallo Spain S.L.U.* | CID002774 | SPAIN |
Tin | Mineracao Taboca S.A.* | CID001173 | BRAZIL |
Tin | Minsur* | CID001182 | PERU |
Tin | Mitsubishi Materials Corporation* | CID001191 | JAPAN |
Tin | Modeltech Sdn Bhd* | CID002858 | MALAYSIA |
Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | CID001314 | THAILAND |
Tin | O.M. Manufacturing Philippines, Inc.* | CID002517 | PHILIPPINES |
Tin | Operaciones Metalurgicas S.A.* | CID001337 | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | PT Aries Kencana Sejahtera* | CID000309 | INDONESIA |
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 Prima Tin* | CID002776 | INDONESIA |
Tin | PT Bangka Serumpun* | CID003205 | 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 Inti Stania Prima* | CID002530 | INDONESIA |
Tin | PT Karimun Mining* | CID001448 | INDONESIA |
Tin | PT Kijang Jaya Mandiri* | CID002829 | INDONESIA |
Tin | PT Menara Cipta Mulia* | CID002835 | INDONESIA |
Tin | PT Mitra Stania Prima* | CID001453 | INDONESIA |
Tin | PT Panca Mega Persada* | CID001457 | INDONESIA |
Tin | PT Premium Tin Indonesia* | CID000313 | INDONESIA |
Tin | PT Prima Timah Utama* | CID001458 | INDONESIA |
Tin | PT Rajehan Ariq* | CID002593 | INDONESIA |
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Tin | PT Refined Bangka Tin* | CID001460 | INDONESIA |
Tin | PT Sariwiguna Binasentosa* | CID001463 | INDONESIA |
Tin | PT Stanindo Inti Perkasa* | CID001468 | INDONESIA |
Tin | PT Sukses Inti Makmur* | CID002816 | INDONESIA |
Tin | PT Sumber Jaya Indah* | CID001471 | INDONESIA |
Tin | PT Timah Tbk Kundur* | CID001477 | INDONESIA |
Tin | PT Timah Tbk Mentok* | CID001482 | INDONESIA |
Tin | PT Tinindo Inter Nusa* | CID001490 | INDONESIA |
Tin | PT Tommy Utama* | CID001493 | INDONESIA |
Tin | Resind Industria e Comercio Ltda.* | CID002706 | BRAZIL |
Tin | Rui Da Hung* | CID001539 | TAIWAN, PROVINCE OF CHINA |
Tin | Soft Metais Ltda.* | CID001758 | BRAZIL |
Tin | Thaisarco* | CID001898 | THAILAND |
Tin | White Solder Metalurgia e Mineracao Ltda.* | CID002036 | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | CID002158 | CHINA |
Tin | Yunnan Tin Company Limited* | CID002180 | CHINA |
Gold | Advanced Chemical Company* | CID000015 | UNITED STATES OF AMERICA |
Gold | Aida Chemical Industries Co., Ltd.* | CID000019 | JAPAN |
Gold | Al Etihad Gold Refinery DMCC* | CID002560 | UNITED ARAB EMIRATES |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G.* | CID000035 | GERMANY |
Gold | Almalyk Mining and Metallurgical Complex (AMMC)* | CID000041 | UZBEKISTAN |
Gold | AngloGold Ashanti Corrego do Sitio Mineracao* | CID000058 | BRAZIL |
Gold | Argor-Heraeus S.A.* | CID000077 | SWITZERLAND |
Gold | Asahi Pretec Corp.* | CID000082 | JAPAN |
Gold | Asahi Refining Canada Ltd.* | CID000924 | CANADA |
Gold | Asahi Refining USA Inc.* | CID000920 | UNITED STATES OF AMERICA |
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Gold | Asaka Riken Co., Ltd.* | CID000090 | JAPAN |
Gold | AU Traders and Refiners* | CID002850 | SOUTH AFRICA |
Gold | Aurubis AG* | CID000113 | GERMANY |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | CID000128 | PHILIPPINES |
Gold | Boliden AB* | CID000157 | SWEDEN |
Gold | C. Hafner GmbH + Co. KG* | CID000176 | GERMANY |
Gold | CCR Refinery - Glencore Canada Corporation* | CID000185 | CANADA |
Gold | Cendres + Metaux S.A.* | CID000189 | SWITZERLAND |
Gold | Chimet S.p.A.* | CID000233 | ITALY |
Gold | Daejin Indus Co., Ltd.* | CID000328 | KOREA, REPUBLIC OF |
Gold | DODUCO Contacts and Refining GmbH* | CID000362 | GERMANY |
Gold | Dowa* | CID000401 | JAPAN |
Gold | DSC (Do Sung Corporation)* | CID000359 | KOREA, REPUBLIC OF |
Gold | Eco-System Recycling Co., Ltd.* | CID000425 | JAPAN |
Gold | Emirates Gold DMCC* | CID002561 | UNITED ARAB EMIRATES |
Gold | Geib Refining Corporation* | CID002459 | UNITED STATES OF AMERICA |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd.* | CID002243 | CHINA |
Gold | HeeSung Metal Ltd.* | CID000689 | KOREA, REPUBLIC OF |
Gold | Heimerle + Meule GmbH* | CID000694 | GERMANY |
Gold | Heraeus Metals Hong Kong Ltd.* | CID000707 | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG* | CID000711 | GERMANY |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | CID000801 | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd.* | CID000807 | JAPAN |
Gold | Istanbul Gold Refinery* | CID000814 | TURKEY |
Gold | Italpreziosi* | CID002765 | ITALY |
Gold | Japan Mint* | CID000823 | JAPAN |
Gold | Jiangxi Copper Co., Ltd.* | CID000855 | CHINA |
Gold | JSC Uralelectromed* | CID000929 | RUSSIAN FEDERATION |
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Gold | JX Nippon Mining & Metals Co., Ltd.* | CID000937 | JAPAN |
Gold | Kazzinc* | CID000957 | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC* | CID000969 | UNITED STATES OF AMERICA |
Gold | Kojima Chemicals Co., Ltd.* | CID000981 | JAPAN |
Gold | Korea Zinc Co., Ltd.* | CID002605 | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC* | CID001029 | KYRGYZSTAN |
Gold | LS-NIKKO Copper Inc.* | CID001078 | KOREA, REPUBLIC OF |
Gold | Marsam Metals* | CID002606 | BRAZIL |
Gold | Materion* | CID001113 | UNITED STATES OF AMERICA |
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 (Suzhou) Ltd.* | CID001147 | CHINA |
Gold | Metalor Technologies S.A.* | CID001153 | SWITZERLAND |
Gold | Metalor USA Refining Corporation* | CID001157 | UNITED STATES OF AMERICA |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V.* | CID001161 | MEXICO |
Gold | Mitsubishi Materials Corporation* | CID001188 | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd.* | CID001193 | JAPAN |
Gold | MMTC-PAMP India Pvt., Ltd.* | CID002509 | INDIA |
Gold | Moscow Special Alloys Processing Plant* | CID001204 | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S.* | CID001220 | TURKEY |
Gold | Nihon Material Co., Ltd.* | CID001259 | JAPAN |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | CID002779 | AUSTRIA |
Gold | Ohura Precious Metal Industry Co., Ltd.* | CID001325 | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)* | CID001326 | RUSSIAN FEDERATION |
Gold | OJSC Novosibirsk Refinery* | CID000493 | RUSSIAN FEDERATION |
Gold | PAMP S.A.* | CID001352 | SWITZERLAND |
Gold | Planta Recuperadora de Metales SpA* | CID002919 | CHILE |
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Gold | Prioksky Plant of Non-Ferrous Metals* | CID001386 | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk* | CID001397 | INDONESIA |
Gold | PX Precinox S.A.* | CID001498 | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd.* | CID001512 | SOUTH AFRICA |
Gold | Royal Canadian Mint* | CID001534 | CANADA |
Gold | SAAMP* | CID002761 | FRANCE |
Gold | Safimet S.p.A* | CID002973 | ITALY |
Gold | Samduck Precious Metals* | CID001555 | KOREA, REPUBLIC OF |
Gold | SAXONIA Edelmetalle GmbH* | CID002777 | GERMANY |
Gold | SEMPSA Joyeria Plateria S.A.* | CID001585 | SPAIN |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | CID001622 | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd.* | CID001736 | CHINA |
Gold | Singway Technology Co., Ltd.* | CID002516 | TAIWAN, PROVINCE OF CHINA |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals* | CID001756 | RUSSIAN FEDERATION |
Gold | Solar Applied Materials Technology Corp.* | CID001761 | TAIWAN, PROVINCE OF CHINA |
Gold | Sumitomo Metal Mining Co., Ltd.* | CID001798 | JAPAN |
Gold | SungEel HiMetal Co., Ltd.* | CID002918 | KOREA, REPUBLIC OF |
Gold | T.C.A S.p.A* | CID002580 | ITALY |
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 | Torecom* | CID001955 | KOREA, REPUBLIC OF |
Gold | Umicore Brasil Ltda.* | CID001977 | BRAZIL |
Gold | Umicore Precious Metals Thailand* | CID002314 | THAILAND |
Gold | Umicore S.A. Business Unit Precious Metals Refining* | CID001980 | BELGIUM |
Gold | United Precious Metal Refining, Inc.* | CID001993 | UNITED STATES OF AMERICA |
Gold | Valcambi S.A.* | CID002003 | SWITZERLAND |
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Gold | Western Australian Mint (T/a The Perth Mint)* | CID002030 | AUSTRALIA |
Gold | WIELAND Edelmetalle GmbH* | CID002778 | GERMANY |
Gold | Yamakin Co., Ltd.* | CID002100 | JAPAN |
Gold | Yokohama Metal Co., Ltd.* | CID002129 | JAPAN |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation* | CID002224 | CHINA |
Tungsten | A.L.M.T. Corp.* | CID000004 | JAPAN |
Tungsten | ACL Metais Eireli* | CID002833 | BRAZIL |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd.* | CID002513 | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | CID000258 | 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 OF AMERICA |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd.* | CID000218 | CHINA |
Tungsten | H.C. Starck Smelting GmbH & Co. KG* | CID002542 | GERMANY |
Tungsten | H.C. Starck Tungsten GmbH* | CID002541 | GERMANY |
Tungsten | Hunan Chenzhou Mining Co., Ltd.* | CID000766 | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji* | CID002579 | CHINA |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd.* | CID000769 | CHINA |
Tungsten | Hydrometallurg, JSC* | CID002649 | RUSSIAN FEDERATION |
Tungsten | Japan New Metals Co., Ltd.* | CID000825 | JAPAN |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | CID002551 | CHINA |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | CID002321 | CHINA |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | CID002318 | CHINA |
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Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | CID002317 | CHINA |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | CID002316 | CHINA |
Tungsten | Kennametal Fallon* | CID000966 | UNITED STATES OF AMERICA |
Tungsten | Kennametal Huntsville* | CID000105 | UNITED STATES OF AMERICA |
Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | CID002319 | CHINA |
Tungsten | Masan Tungsten Chemical LLC (MTC)* | CID002543 | VIET NAM |
Tungsten | Moliren Ltd.* | CID002845 | RUSSIAN FEDERATION |
Tungsten | Niagara Refining LLC* | CID002589 | UNITED STATES OF AMERICA |
Tungsten | Philippine Chuangxin Industrial Co., Inc.* | CID002827 | PHILIPPINES |
Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City* | CID002815 | CHINA |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd.* | CID001889 | VIET NAM |
Tungsten | Unecha Refractory metals plant* | CID002724 | RUSSIAN FEDERATION |
Tungsten | Wolfram Bergbau und Hutten AG* | CID002044 | AUSTRIA |
Tungsten | Woltech Korea Co., Ltd.* | CID002843 | KOREA, REPUBLIC OF |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | CID002320 | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd.* | CID002082 | CHINA |
Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | CID002830 | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | CID002095 | CHINA |
*Conformant to the RMAP as of March 5, 2018
**Active in the RMAP as of March 5, 2018
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Table 3: Possible Countries of Origin for Identified SORs
Mineral | Countries of Origin may Include |
Gold | Argentina, Armenia, Australia, Azerbaijan, Benin, Bolivia, Botswana, Brazil, Burkina Faso, Canada, Chile, China, Colombia, Cote de Ivory, Cyprus, Democratic Republic of the Congo*, Dominican Republic, Ecuador, Egypt, Eritrea, Ethiopia, Finland, Georgia, Ghana, Guatemala, Guinea, Guyana, Indonesia, Iran**, Ivory Coast, Kazakhstan, Kenya, Laos, Lebanon, Malaysia, Mali, Mauritania, Mexico, Mongolia, Morocco, Mozambique, Namibia, Nicaragua, Niger, Papua New Guinea, Peru, Philippines, Puerto Rico, Russia, Saudi Arabia, Senegal, Slovakia, Solomon Islands, South Africa, Spain, Suriname, Swaziland, Sweden, Taiwan, Tanzania*, Thailand, Togo, Turkey, United Arab Emirates, Zambia*, United States, Uzbekistan, Zimbabwe. |
Tantalum | Australia, Austria, Bolivia, Brazil, Burundi*, China, Colombia, Democratic Republic of the Congo*, Ethiopia, Guinea, India, Madagascar, Malaysia, Mozambique, Nigeria, Russia, Sierra Leone, Thailand, Rwanda*. |
Tin | Australia, Bolivia, Brazil, Burundi*, Chins, Colombia, Democratic Republic of the Congo*, Guinea, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Portugal, Russia, Rwanda*, Taiwan, Thailand, Uganda*, United Kingdom, Venezuela. |
Tungsten | Australia, Bolivia, Brazil, Burundi*, China, Colombia, Democratic Republic of the Congo*, Guinea, Indonesia, Laos, Malaysia, Mongolia, Myanmar, Nigeria, Peru, Russia, Rwanda*, Taiwan, Thailand, United Kingdom. |
*DRC or Adjoining Country
**Minerals from this location were substantially transformed before being incorporated into finished products. Such a substantial transformation of the minerals occurred outside of the United States in a third country by a person other than a United States person.
2019 PLANNED IMPROVEMENTS
Qorvo is committed to the responsible sourcing of conflict minerals and will continue to advance the implementation of our conflict mineral program with relevant suppliers.
For the 2019 reporting year, we plan to:
• | Continue working with suppliers who have provided incomplete or inaccurate sourcing information and drive them to 100% identification of the actual SORs in the supply chain. |
• | Add conflict minerals to Qorvo’s Social Responsibility Supplier Monitoring procedure. |
• | Add conflict minerals to Qorvo’s Social Responsibility Communication procedure. |
• | Continue encouraging smelters and refiners to participate in the RMAP. |
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,
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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.
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Exhibit A
INDEPENDENT AUDITOR’S REPORT
INDEPENDENT PRIVATE SECTOR AUDIT REPORT
DODD FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT, SECTION 1502
QORVO INC.
To the Board of Directors
Resource Consulting Services Limited (“RCS Global” or “RCS”) conducted an Independent Private Sector Audit (IPSA) of the Qorvo Inc. (“the Company”) Conflict Minerals Report for the reporting period of January 1 to December 31, 2018. We examined evidence relating to the audit objectives set forth in 17 CFR Part 249b.400, Section 1, Item 1.01, which state that the auditor is to express an opinion or conclusion as to:
1) Whether the design of the Company’s due diligence framework as set forth in the Sections on Company Management Systems and Due Diligence in the Company’s Conflict Minerals Report for the reporting period from January 1 to December 31, 2018, is in conformity, in all material respects, with the criteria set forth in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition 2016 (“OECD Guidance”), and
2) Whether the Company’s description of the due diligence measures it performed, as set forth in the Section on Due Diligence in the Company’s Conflict Minerals Report for the reporting period from January 1 to December 31, 2018, is consistent with the due diligence process that the Company undertook.
Management is responsible for the design of the Company’s due diligence framework and the description of the Company’s due diligence measures set forth in the Company’s Conflict Minerals Report, and performance of the due diligence measures. The opinion or conclusion in this audit report is in relation to the two audit objectives. These audit objectives are narrowly defined and do not include the auditor’s opinion on:
• | The consistency of the due diligence measures that the Company performed with either the design of the Company’s due diligence framework or the OECD Due Diligence Guidance. |
• | The completeness of the Company’s description of the due diligence measures performed. |
• | The suitability of the design or operating effectiveness of the Company’s due diligence process. |
• | The Company’s reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof. |
• | The Company’s conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products. |
Consequently, we do not express an opinion or conclusion on the matters listed above or any other matters included in any section of the Company’s Conflict Minerals Report other than the design of the Company’s due diligence framework and the Company’s description of the due diligence measures it performed as set forth in the Sections mentioned in the audit objectives.
We conducted this performance audit in accordance with generally accepted government auditing standards, in particular Chapters 1, 2, 3, 6 and 7 of the U.S. Government Accountability Office Generally Accepted Government Auditing
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Standards, Revision of December 2011. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.
For the first audit objective, we reviewed policies, processes and procedures describing the design of the due diligence framework and conducted interviews with the persons directly responsible for the conflict minerals program and the design of the due diligence framework at the Company. For the second audit objective, we reviewed records supporting the implementation of due diligence measures as described in the Conflict Minerals Report and conducted interviews with the persons of the Company involved in the implementation of these measures. For the second audit objective, we adopted a sampling approach for the review of records, taking into account the type of mineral, the total population as well as type and level of risk associated with sourcing practices of supply chain actors.
We believe that the evidence obtained provides a reasonable basis for our findings based on our audit objectives.
Management was provided an opportunity to review and offer comments on a draft of this report and had no comments to the draft report.
In our opinion,
• | The design of the Company’s due diligence framework for the reporting period from January 1 to December 31, 2018, as set forth in the Company’s Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and |
• | The Company’s description of the due diligence measures it performed as set forth in the Conflict Minerals Report for the reporting period from January 1 to December 31, 2018, is consistent with the due diligence process that the Company undertook. |
Resource Consulting Services Limited
London, 05 April 2019
MSc. Josue Ruiz
Auditor
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