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, 2019.
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/node/5876.
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 29, 2020 | |
Mark J. Murphy | |||
Chief Financial Officer | |||
Exhibit 1.01
QORVO, INC.
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2019
INTRODUCTION
Qorvo, Inc. (herein referred to as the “Company”, “Qorvo”, “we”, “us”, or “our”) presents this Conflict Minerals Report (“CMR”) for the year ended December 31, 2019 (“Reporting Period”), pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). Rule 13p-1 was adopted by the Securities and Exchange Commission (“SEC”) to impose 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. The SEC defines “conflict minerals” as 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”) 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 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 may not be solely from recycled or scrap sources, the registrant must exercise due diligence to determine if the conflict minerals used directly or indirectly financed or benefited armed groups in the Covered Countries.
COMPANY 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. Visit www.qorvo.com to learn how Qorvo connects the world.
During the Reporting Period, Qorvo completed its acquisition of Active-Semi International, Inc. (“Active-Semi”) as well as its acquisition of the remaining issued and outstanding capital of Cavendish Kinetics Limited (“Cavendish”). Conflict mineral due diligence activities for both Active-Semi and Cavendish, each of which were privately held companies, are completely integrated into Qorvo’s responsible minerals program, and included in the CMR subsections below.
Products Covered in this Report
For the year ended December 31, 2019 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.
Mobile Products
MP is a global supplier of cellular, ultra-wide band and Wi-Fi solutions for a variety of high-volume markets, including smartphones, wearables, laptops, tablets and IoT applications.
Infrastructure and Defense Products
IDP is a global supplier of RF, system-on-a-chip and power management solutions for wireless infrastructure, defense, smart home, automotive and other IoT applications.
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OVERVIEW
Qorvo is committed to the responsible sourcing of minerals, and strives to conduct activities that respect and support human rights throughout its global supply chain. We have worked extensively for 11 years on the issue of conflict minerals, and recognize that collaborative efforts among industry stakeholders are needed to identify and mitigate the risks associated with 3TG mineral extraction in the Covered Countries. Qorvo is a member of the Responsible Minerals Initiative (RMI), where we regularly collaborate with industry peers and other stakeholders to address 3TG related issues and promote responsible mineral sourcing.
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. Qorvo is far removed from the mines and SORs in its global 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 Due Diligence Guidance”). Due to our position in the supply chain, we rely on our “relevant suppliers” – direct 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 Qorvo products, and we collaborate with industry peers and other stakeholders to meet our responsible mineral goals and customer expectations. 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.
For the Reporting Period, in accordance with Rule 13p-1, we 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 of these conflict minerals, as described in this CMR below.
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
For the year ended December 31, 2019, Qorvo’s RCOI process began with identifying our relevant 3TG suppliers and surveying those suppliers with the use of the RMI developed Conflict Minerals Reporting Template (“CMRT”). Relevant suppliers were requested to identify the smelters and refiners that processed the 3TG used in their 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 SORs identified by our suppliers against the lists of processing facilities that are validated by a third-party audit program such as the RMI’s Responsible Minerals Assurance Process (“RMAP”), London Bullion Market Association (“LBMA”) Responsible Gold Program, or the Responsible Jewellery Council (“RJC”) Chain-of-Custody Certification. We obtained country of origin information for the identified SORs from sources including relevant supplier CMRT responses, the RMI’s RCOI report for member companies, and publicly available resources, if we determined such publicly available information to be reliable.
Results of RCOI
Qorvo conducted a 3TG survey of 121 relevant suppliers during the Reporting Period. As of March 13, 2020, the results of our RCOI were as follows:
• | 100% of relevant suppliers provided a CMRT response to our 3TG survey request. |
• | Relevant suppliers identified 223 “eligible” SORs which may process the conflict minerals contained in components and/or materials supplied to Qorvo. |
• | We know or have reason to believe that some of the 3TG processed by 43 of the 223 SORs may have originated in the Covered Countries. |
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DUE DILIGENCE DESIGN
Qorvo’s responsible minerals program includes due diligence measures for the use of 3TG in its global supply chain and is designed to conform to OECD Due Diligence Guidance as it relates to our position in the supply chain as a “downstream” company. The design of Qorvo’s responsible minerals program, in alignment with the OECD’s five-step framework, is outlined in the sections below.
(1) Establish Strong Company Management Systems
Conflict Minerals Policy
Qorvo continues to maintain a policy for the responsible sourcing of conflict minerals. This policy is made publicly available at http://www.qorvo.com/about-us/corporate-social-responsibility/our-program, and was updated in 2019 to include our expanded commitment to responsible mineral sourcing.
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, led by Qorvo’s Global Sourcing organization, to implement Qorvo’s responsible minerals policy. This team regularly reports on the status of Qorvo’s 3TG due diligence efforts 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 with the use of the CMRT. The goal of this system is to collect the necessary information from relevant suppliers to identify the SORs used in Qorvo’s supply chain and to obtain the information necessary to meet legal and customer reporting requirements.
Supplier Engagement
We regularly communicate elements of our responsible minerals program to suppliers through multiple channels, including our responsible minerals database and Qorvo’s external website. This communication includes related policies, expectations and requirements, as well as the results of our CMRT reviews. Our database is used to assess supplier CMRT 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 responsible 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 responsible mineral sourcing. These terms are available on our website at: https://www.qorvo.com/support/supplier-resources/.
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 from our Corporate, Social and Environmental Responsibility page at https://www.qorvo.com/about-us/corporate-social-responsibility/.
For grievances related to conflict minerals, Qorvo employees and external parties may also submit concerns or information to ConflictMinerals@qorvo.com. The Responsible Minerals Specialist will then route the grievance to our Compliance Officer at ComplianceOfficer@qorvo.com for further investigation.
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In addition to the above channels, Qorvo also monitors the RMI’s Grievance Mechanism Report and RMI sub-team discussions for issues that may be applicable to the Company: http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.
(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 us with components and/or materials containing 3TG. Using the industry-standard CMRT, we conduct bi-annual surveys or “CMRT campaigns” of our relevant suppliers to identify 3TG sourcing information, including the smelters and refiners that processed the conflict minerals used in Qorvo products, and the country of origin information of those conflict minerals. We evaluate supplier responses and contact those suppliers whose CMRTs we identify as containing possible risks and/or incomplete or potentially inaccurate data.
Identify and Assess Supply Chain Risks
We maintain a database to analyze supplier CMRT data based on criteria established by Qorvo. This analysis is designed to identify potential risks in the supply chain related to 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 SORs that have not been validated by a third-party audit program. |
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 provided in their CMRTs.
Qorvo Supplier Specification (SPE-001288)
Qorvo has developed a detailed specification to communicate to suppliers our expectations related to responsible mineral sourcing. 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 relevant 3TG SORs used in their supply chains are validated by a third-party audit program. |
• | Respond to all Qorvo requests for further information regarding their CMRT submissions and/or reported SORs. |
• | Implement the above referenced requirements with their relevant sub-tier suppliers. |
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Implement a Risk Management Plan
Qorvo has developed a risk mitigation plan to help bring suppliers into compliance with our 3TG requirements. Mitigation efforts may include, but are not limited to: communicating the identified risk(s) 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.
Monitor and Record Progress
Risks related to relevant suppliers and 3TG sourcing are monitored and tracked in our responsible minerals database. This tool allows Qorvo 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 the risks and their potential 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 financial resources, expertise, or leverage 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 this CMR 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 Available Reports
Qorvo’s Responsible Minerals Policy and additional information related to Qorvo’s responsible minerals program are publicly available on our website at: http://www.qorvo.com/about-us/corporate-social-responsibility/our-program.
In addition, our RCOI and due diligence practices are communicated through Qorvo’s Form SD and CMR, which are filed annually with the SEC. These reports are available at: https://ir.qorvo.com/node/5876 and https://www.qorvo.com/about-us/corporate-social-responsibility/our-program.
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DUE DILIGENCE MEASURES PERFORMED
For the Reporting Period, Qorvo performed the following due diligence activities on the source of the 3TG we have reason to believe may have originated in the Covered Countries:
• | Communicated our responsible minerals policy, expectations and requirements to relevant suppliers. |
• | Conducted a bi-annual survey of relevant suppliers to determine whether any of the 3TG used in Qorvo products originated in the Covered Countries. |
• | Maintained a 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 our CMRT review criteria. |
• | 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 meeting those requirements. |
• | Performed mitigation efforts with relevant suppliers we identified as not meeting Qorvo requirements to bring them into compliance with those requirements. |
• | Added a link to Qorvo’s grievance mechanism to our Corporate, Social and Environmental Responsibility webpage. |
• | Added categories to the report type menu for filing a grievance on Qorvo’s EthicsPoint website. |
• | Reported on the status of Qorvo’s responsible minerals program to senior management. |
• | 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/node/5876. |
• | Obtained an independent private sector audit of this CMR, 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 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 Reporting Period. As a result, our suppliers identified 259 SORs as potential sources of the 3TG believed to be in Qorvo’s 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.
Of the 259 potential SORs identified by our suppliers, 36 were subsequently found to be inoperative in 2019, and therefore not eligible for the RMAP. These facilities are not included in this report as “processing facilities” and are not included in the section below.
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Processing Facilities (“SORS”) Identified for the Reporting Period
This CMR’s use of the terms “smelters and refiners” and “processing facilities” refers to 3TG entities that 1) were reported in a supplier’s CMRT; 2) determined to meet the RMI’s definition of a smelter or refiner; and 3) determined to be operational in 2019. In some cases our suppliers reported facilities that Qorvo believes are no longer operational. These facilities are not included in this report as “processing facilities” and are not included in the data below. However, we continue to conduct research on such entities and work with our relevant suppliers to improve their reported information.
Figure 1: RMAP Participation Status of Identified SORs by Reporting Year
Participation status is defined in the following manner:
• | Conformant – SOR has been validated by a third-party audit and found to be conformant with relevant audit protocols including the RMAP, LBMA or RJC. |
• | Active – SOR is engaged by not yet conformant to a third-party audit program. |
• | Not Participating – SOR has not yet committed to third-party verification of their mineral procurement processes. |
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Table 1: Identified SORs with Covered Country Sourcing*
All smelters and refiners believed to source from the Covered Countries are conformant to the RMAP as of March 13, 2020.
Mineral | Total SORs Identified | Believed to Source from the Covered Countries | Percentage |
Tin | 44 | 7 | 16% |
Tantalum | 36 | 23 | 64% |
Tungsten | 40 | 10 | 25% |
Gold | 103 | 4 | 4% |
Total | 223 | 44 | 20% |
*Data is based on the RMI’s RCOI report dated January 31, 2020.
Table 2: List of Identified SORs in Qorvo’s Supply Chain as of March 13, 2020
All SORs believed to be in in Qorvo’s supply chain are conformant to the RMAP as of March 13, 2020
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 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 |
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 |
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Mineral | Smelter Name | Smelter ID | Smelter Location |
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 | 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 | Power Resources Ltd. | CID002847 | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF |
Tantalum | QuantumClean | CID001508 | UNITED STATES OF AMERICA |
Tantalum | Resind Industria e Comercio Ltda. | CID002707 | BRAZIL |
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 |
Tantalum | RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 | CHINA |
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 | Dowa | CID000402 | JAPAN |
Tin | EM Vinto | CID000438 | BOLIVIA (PLURINATIONAL STATE OF) |
Tin | Fenix Metals | CID000468 | POLAND |
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 |
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Mineral | Smelter Name | Smelter ID | Smelter Location |
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 |
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 | 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 Artha Cipta Langgeng | CID001399 | INDONESIA |
Tin | PT ATD Makmur Mandiri Jaya | CID002503 | INDONESIA |
Tin | PT Mitra Stania Prima | CID001453 | INDONESIA |
Tin | PT Refined Bangka Tin | CID001460 | INDONESIA |
Tin | PT Timah Tbk Kundur | CID001477 | INDONESIA |
Tin | PT Timah Tbk Mentok | CID001482 | 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 | Thai Nguyen Mining and Metallurgy Co., Ltd. | CID002834 | VIET NAM |
Tin | Thaisarco | CID001898 | THAILAND |
Tin | Tin Technology & Refining | CID003325 | UNITED STATES OF AMERICA |
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 |
Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 | CHINA |
Gold | 8853 S.p.A. | CID002763 | ITALY |
Gold | Advanced Chemical Company | CID000015 | UNITED STATES OF AMERICA |
Gold | Aida Chemical Industries Co., Ltd. | CID000019 | JAPAN |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | CID000035 | GERMANY |
10
Mineral | Smelter Name | Smelter ID | Smelter Location |
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 |
Gold | Asaka Riken Co., Ltd. | CID000090 | JAPAN |
Gold | AU Traders and Refiners | CID002850 | SOUTH AFRICA |
Gold | Aurubis AG | CID000113 | GERMANY |
Gold | Bangalore Refinery | CID002863 | INDIA |
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 | Chugai Mining | CID000264 | JAPAN |
Gold | DODUCO Contacts and Refining GmbH | CID000362 | GERMANY |
Gold | Dowa | CID000401 | JAPAN |
Gold | DS PRETECH Co., Ltd. | CID003195 | KOREA, REPUBLIC OF |
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 | 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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Mineral | Smelter Name | Smelter ID | Smelter Location |
Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | JAPAN |
Gold | Kazzinc | CID000957 | KAZAKHSTAN |
Gold | Kennecott Utah Copper LLC | CID000969 | UNITED STATES OF AMERICA |
Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 | POLAND |
Gold | Kojima Chemicals Co., Ltd. | CID000981 | JAPAN |
Gold | Korea Zinc Co., Ltd. | CID002605 | KOREA, REPUBLIC OF |
Gold | Kyrgyzaltyn JSC | CID001029 | KYRGYZSTAN |
Gold | L'Orfebre S.A. | CID002762 | ANDORRA |
Gold | LS-NIKKO Copper Inc. | CID001078 | KOREA, REPUBLIC OF |
Gold | HeeSung Metal Ltd. | CID000689 | 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 |
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 | REMONDIS PMR B.V. | CID002582 | NETHERLANDS |
Gold | Royal Canadian Mint | CID001534 | CANADA |
Gold | SAAMP | CID002761 | FRANCE |
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Mineral | Smelter Name | Smelter ID | Smelter Location |
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 |
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 | Smelter not listed | CID002502 | VIET NAM |
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 Haichuang Tungsten Co., Ltd. | CID002645 | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CID000875 | CHINA |
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Mineral | Smelter Name | Smelter ID | Smelter Location |
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 |
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 | KGETS Co., Ltd. | CID003388 | KOREA, REPUBLIC OF |
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 | 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 |
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Table 3: Possible Countries of Origin for Identified SORs
Countries from which the 3TG used in Qorvo’s products may have originated based on the RMI’s RCOI report dated January 31, 2020.
Argentina | Guinea | Portugal |
Australia | Guyana | Puerto Rico |
Austria | Honduras | Russian Federation |
Azerbaijan | India | Rwanda* |
Benin | Indonesia | Saudi Arabia |
Bolivia | Iran** | Senegal |
Bolivia (Plurinational State of) | Ivory Coast | Serbia |
Botswana | Japan | Sierra Leone |
Brazil | Kazakhstan | Slovakia |
Burkina Faso | Kenya | Solomon Islands |
Burundi* | Laos | Somaliland |
Canada | Liberia | South Africa |
Chile | Madagascar | Spain |
China | Malaysia | Suriname |
Colombia | Mali | Swaziland |
Congo, Democratic Republic of the* | Mauritania | Sweden |
Cuba | Mexico | Taiwan |
Cyprus | Mongolia | Tajikistan |
Dominican Republic | Morocco | Tanzania* |
Ecuador | Mozambique | Thailand |
Egypt | Myanmar | Togo |
Eritrea | Namibia | Turkey |
Ethiopia | Netherlands | Uganda* |
Fiji | New Zealand | United Kingdom of Great Britain and Northern Ireland |
Finland | Nicaragua | United States of America |
France | Niger | Uruguay |
Georgia | Nigeria | Uzbekistan |
Germany | Papua New Guinea | Vietnam |
Ghana | Peru | Zambia |
Guatemala | Philippines | Zimbabwe |
*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.
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2020 PLANNED IMPROVEMENTS
Qorvo is committed to the responsible sourcing of 3TG and will continue to advance the implementation of our responsible mineral program with relevant suppliers.
For the 2020 reporting period, we plan to:
• | Continue working with suppliers who may provide incomplete or inaccurate sourcing information and drive them to 100% identification of the actual SORs in the supply chain. |
• | Continue encouraging smelters and refiners to participate in the RMAP. |
• | Continue to enhance our supplier corrective action process for 3TG related issues. |
• | Continue to improve the verification process for supplier 3TG reporting. |
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.
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Exhibit A
INDEPENDENT AUDITOR’S REPORT
To the Board of Directors
RCS Global Limited (“RCS Global” or “RCS”) conducted an Independent Private Sector Audit (IPSA) of the Conflict Minerals Report of Qorvo, Inc. (the "Company") for the reporting period of January 1 to December 31, 2019. 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 measures as set forth in the Company's Conflict Minerals Report for the reporting period from January 1 to December 31, 2019, is in conformity with, in all material respects, 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 Conflict Minerals Report for the reporting period from January 1 to December 31, 2019, 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 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 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 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 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 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.
17
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, 2019, as set forth in the Conflict Minerals Report is in conformity with, in all material respects, the OECD 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, 2019, is consistent with the due diligence process that the Company undertook. |
RCS Global Limited
London, 22 April 2020
MSc. Josue Ruiz
Auditor
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