SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Specialized Disclosure Report
(Exact name of registrant as specified in its charter)
(State or other jurisdiction
7628 Thorndike Road
Greensboro, North Carolina 27409-9421
(Address of principal executive offices)
|Grant A. Brown||(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:
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended .
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 Qorvos 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|| |
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 Resource Extraction Issuer Disclosure
|Item 2.01|| |
Resource Extraction Issuer Disclosure and Report
Section 3 Exhibits
|Item 3.01|| |
|1.01||Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.|
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.
|By:||Date: May 26, 2022|
Grant A. Brown
|Vice President of Treasury and Interim Chief Financial Officer|
CONFLICT MINERALS REPORT
FOR THE YEAR ENDED DECEMBER 31, 2021
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, 2021 (Reporting Period), pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (Rule 13p-1). This CMR should be read in conjunction with the definitions contained in the instructions to Form SD and related rules of the Securities and Exchange Commission (SEC). 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).
Qorvo (Nasdaq: QRVO) is a global leader in the development and commercialization of technologies and products for wireless, wired and power markets. We have two reportable segments: Mobile Products (MP) and Infrastructure and Defense Products (IDP). MP is a global supplier of cellular, ultra-wideband 802.15.4z, Wi-Fi and other wireless solutions for a variety of applications, including smartphones, wearables, laptops, tablets and the Internet of Things (IoT). IDP is a global supplier of radio frequency (RF), system-on-a-chip and power management solutions for a wide range of markets, including cellular and IT infrastructure, automotive, renewable energy, defense and IoT. Our MP segment supplies RF solutions to global consumer product companies, and our IDP segment supplies a more diverse portfolio of products with generally longer life cycles to a broader base of customers and end markets. Visit www.qorvo.com to learn how Qorvo connects the world.
During the Reporting Period, Qorvo completed its acquisition of NextInput, Inc. (NextInput), a provider of microelectromechanical system-based sensing products, and United Silicon Carbide, Inc. (United SiC), a provider of silicon carbide power products. Conflict mineral due diligence activities for both NextInput and United SiC, each of which were privately held companies, are completely integrated into Qorvos responsible minerals program, and included in the CMR subsections below.
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 13 years on the issue of conflict minerals and recognize that collaborative efforts among industry stakeholders are needed to identify and mitigate the potential risks associated with 3TG extraction in the Democratic Republic of the Congo or an adjoining country (collectively referred to as 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 mine sites 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 suppliers 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. Suppliers are requested to assist in our Reasonable Country of Origin Inquiry (RCOI) and due diligence efforts, including the identification of the smelters and refiners who process 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, 2021, Qorvos RCOI process began with identifying our relevant suppliers and surveying those suppliers with the RMI developed Conflict Minerals Reporting Template (CMRT). We identified relevant suppliers based on the unique circumstance of the Companys operating and reportable segments, taking a risk-based approach to consider: 1) the potential 3TG content in the components and/or materials provided; and 2) revenue for the Reporting Period.
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, accuracy, and degree of supply chain risk, and contacted those suppliers whose CMRTs we identified to contain potential risks, and/or incomplete or potentially inaccurate data. We also reviewed the SORs identified by our suppliers against the lists of processing facilities that were validated by a third-party audit program such as the RMIs 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 RMIs 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 151 relevant suppliers, including suppliers from the former NextInput and United SiC supply chains, for the Reporting Period.
As of April 22, 2022, the results of our RCOI were as follows:
99% of relevant suppliers provided a CMRT response to our 3TG survey request.
Relevant suppliers identified 240 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 45 of the 240 SORs may have originated in the Covered Countries and not solely from recycled or scrap sources.
We had one supplier that did not provide a response to our 3TG survey, and one additional supplier that has not yet identified all the SORs supplying 3TG to its supply chain. Due to these limitations in our sourcing data, we were unable to determine the origin of all the conflict minerals used in our products for the Reporting Period. Qorvos due diligence with these suppliers is ongoing and we continue to work our escalation process to drive improvements in their responses.
As of April 22, 2022, all SORs that we currently know or have reason to believe may source from the Covered Countries have been validated as conformant to the RMAP.
DUE DILIGENCE DESIGN
Qorvos 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.
DUE DILIGENCE MEASURES PERFORMED
In alignment with the OECDS five-step framework for risk-based due diligence, Qorvo performed the following activities to exercise due diligence on the source of the 3TG used in our products for the Reporting Period.
(1) Establish Strong Company Management Systems
Maintained a Responsible Minerals Policy, which includes Qorvos commitment to use responsibly sourced 3TG from the Covered Countries. This Policy is made publicly available on our website at https://www.qorvo.com/about-us/corporate-social-responsibility/our-program. 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.
Maintained an internal team, led by Qorvos Environmental, Social and Governance team, to implement our responsible minerals program, ensure relevant suppliers are made aware of Qorvos policy and expectations for responsible minerals sourcing, and regularly report on the status of Qorvos 3TG due diligence efforts to senior management and other relevant Qorvo employees.
Maintained a process to achieve control and transparency over our 3TG supply chain, which utilizes the CMRT and supplier engagement to identify the SORs used in Qorvos supply chain, and to obtain the 3TG information necessary to meet legal and customer reporting requirements.
Communicated our Responsible Minerals Policy, expectations and requirements to relevant suppliers using multiple channels, including our responsible minerals database and Qorvos external website. Specific requirements related to conflict minerals are also included in Qorvos standard Purchase Order Terms and Conditions, which are available on our website at https://www.qorvo.com/support/supplier-resources.
Maintained a whistleblower policy and our existing grievance mechanism to provide open and effective channels of communication, where employees and other parties can submit concerns regarding ethical issues, or any grievance related to Qorvo policies and procedures. Our whistleblower policy and grievance channel can be accessed from Qorvos Corporate, Social and Environmental Responsibility web page at https://www.qorvo.com/about-us/corporate-social-responsibility.
Monitored the RMIs Minerals Grievance Platform, and RMI sub-team discussions for 3TG related issues that could be applicable to Qorvos supply chain: http://www.responsiblemineralsinitiative.org/rmap/grievance-mechanism.
(2) Identify and Assess Risks in the Supply Chain
Conducted bi-annual surveys or CMRT campaigns of our relevant suppliers to identify our 3TG sourcing information, including the smelters and refiners that processed the conflict minerals used in Qorvo products for the Reporting Period, and the country-of-origin information for those conflict minerals.
Maintained a database and process to track communications with relevant suppliers, analyze the CMRTs provided by relevant suppliers, aggregate supplier CMRT data for Qorvo reporting, and follow-up with suppliers whose CMRTs we identified to contain potential supply chain risks and/or incomplete or inaccurate data.
Reviewed the SOR data provided by our suppliers against the list of processing facilities that have received a conformant designation from an independent third-party audit program (herein referred to as conformant SORs).
Compared the conformant SORs reported by our suppliers to the RMIs 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
Maintained a supplier monitoring procedure, which is designed to identify and mitigate potential risks presented by relevant suppliers not meeting our expectations for the responsible sourcing of conflict minerals.
Contacted suppliers whose CMRT contained incomplete or potentially inaccurate information to request additional clarification to ensure accuracy of the 3TG data reported.
Provided resources to relevant suppliers to increase awareness of Qorvos expectations and requirements for responsible mineral sourcing and to reduce the risk of inaccurate information received from our suppliers.
Monitored potential supply chain risks related to relevant suppliers and their 3TG sourcing data in our responsible minerals database.
Performed mitigation efforts with relevant suppliers identified as not meeting Qorvos requirements to help bring them into compliance.
Contacted a portion of SORs identified in our supply chain to encourage their participation in the RMAP.
Provided progress updates to senior management summarizing the 3TG data received from our suppliers during Qorvos bi-annual CMRT campaigns, and if necessary, the status of any ongoing mitigation efforts.
(4) Support Independent Third-Party Audits of SOR Due Diligence
Utilized 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.
Maintained our membership and participation in the RMI, where we were able to contribute to the organizations ongoing work in identifying and assessing the sourcing practices of SORs. Qorvo leads the RMIs Smelter Data Management team, which maintains the research data gathered and reported on 3TG processing facilities. We also participate on teams that determine if facilities meet the RMIs 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
Communicated the results of our RCOI and due diligence for the Reporting Period through Qorvos 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.
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 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 246 SORs as potential sources of the 3TG believed to be in Qorvos 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 246 potential SORs identified by our suppliers, 6 were subsequently found to be inoperative in 2021, and therefore not eligible for the RMAP. These facilities are not included in this report as processing facilities and are not included in the sections below.
Processing Facilities (SORS) Identified for the Reporting Period
The use of the terms smelters and refiners and processing facilities throughout this CMR refers to 3TG entities that 1) were reported in a suppliers CMRT for the Reporting Period; 2) determined to meet the RMIs definition of a smelter or refiner; and 3) determined to be operational in 2021. 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 due diligence on such entities and work with our relevant suppliers to improve the quality of the 3TG data reported to Qorvo.
Figure 1: RMAP Participation Status of Identified SORs by Reporting Year
For the purposes of this CMR, participation status is defined in the following manner:
Conformant SOR has been validated by a third-party audit and found to be conformant to relevant audit protocols including the RMAP, LBMA or RJC.
Active SOR is engaged and participating in a third-party audit program but has not yet completed the audit.
Non-Participating SOR has not yet committed to third-party verification of their responsible mineral sourcing processes.
Figure 2: RMAP Participation Status* by Metal for the Reporting Period
Data is based on smelter participation status as of March 1, 2022.
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 April 22, 2022.
|Total SORs Identified||Believed to Source from
the Covered Countries
Data is based on the RMIs RCOI report from January 28, 2022.
Table 2: List of Identified SORs in Qorvos Supply Chain as of April 22, 2022
|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||Almalyk Mining and Metallurgical Complex (AMMC)||CID000041||UZBEKISTAN|
|Gold||AngloGold Ashanti Corrego do Sitio Mineracao||CID000058||BRAZIL|
|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||Bangko Sentral ng Pilipinas (Central Bank of the Philippines)||CID000128||PHILIPPINES|
|Gold||C. Hafner GmbH + Co. KG||CID000176||GERMANY|
|Gold||CCR Refinery - Glencore Canada Corporation||CID000185||CANADA|
|Gold||Cendres + Metaux S.A.||CID000189||SWITZERLAND|
|Gold||DODUCO Contacts and Refining GmbH||CID000362||GERMANY|
|Gold||DSC (Do Sung Corporation)||CID000359||KOREA, REPUBLIC OF|
|Gold||Eco-System Recycling Co., Ltd. East Plant||CID000425||JAPAN|
|Gold||Eco-System Recycling Co., Ltd. North Plant||CID003424||JAPAN|
|Gold||Eco-System Recycling Co., Ltd. West Plant||CID003425||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||Guangdong Jinding Gold Limited||CID002312||CHINA|
|Gold||Heimerle + Meule GmbH||CID000694||GERMANY|
|Gold||Heraeus Germany GmbH Co. KG||CID000711||GERMANY|
|Gold||Heraeus Metals Hong Kong Ltd.||CID000707||CHINA|
|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||Jiangxi Copper Co., Ltd.||CID000855||CHINA|
|Gold||JSC Novosibirsk Refinery||CID000493||RUSSIAN FEDERATION|
|Gold||JSC Uralelectromed||CID000929||RUSSIAN FEDERATION|
|Gold||JX Nippon Mining & Metals Co., Ltd.||CID000937||JAPAN|
|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||LS-NIKKO Copper Inc.||CID001078||KOREA, REPUBLIC OF|
|Gold||LT Metal Ltd.||CID000689||KOREA, REPUBLIC OF|
|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||Navoi Mining and Metallurgical Combinat||CID001236||UZBEKISTAN|
|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||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||Samduck Precious Metals||CID001555||KOREA, REPUBLIC OF|
|Gold||SAXONIA Edelmetalle GmbH||CID002777||GERMANY|
|Gold||SEMPSA Joyeria Plateria S.A.||CID001585||SPAIN|
|Gold||Shandong Gold Smelting Co., Ltd.||CID001916||CHINA|
|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||Tanaka Kikinzoku Kogyo K.K.||CID001875||JAPAN|
|Gold||Tokuriki Honten Co., Ltd.||CID001938||JAPAN|
|Gold||Torecom||CID001955||KOREA, REPUBLIC OF|
|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||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|
|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||H.C. Starck Hermsdorf GmbH||CID002547||GERMANY|
|Tantalum||H.C. Starck Inc.||CID002548||UNITED STATES OF AMERICA|
|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 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 de Mexico||CID002539||MEXICO|
|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||Solikamsk Magnesium Works OAO||CID001769||RUSSIAN FEDERATION|
|Tantalum||Taki Chemical Co., Ltd.||CID001869||JAPAN|
|Tantalum||TANIOBIS Co., Ltd.||CID002544||THAILAND|
|Tantalum||TANIOBIS Japan Co., Ltd.||CID002549||JAPAN|
|Tantalum||TANIOBIS Smelting GmbH & Co. KG||CID002550||GERMANY|
|Tantalum||Telex Metals||CID001891||UNITED STATES OF AMERICA|
|Tantalum||Ulba Metallurgical Plant JSC||CID001969||KAZAKHSTAN|
|Tantalum||XIMEI RESOURCES (GUANGDONG) LIMITED||CID000616||CHINA|
|Tantalum||XinXing HaoRong Electronic Material Co., Ltd.||CID002508||CHINA|
|Tantalum||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||CV Venus Inti Perkasa||CID002455||INDONESIA|
|Tin||EM Vinto||CID000438||BOLIVIA (PLURINATIONAL STATE OF)|
|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||HuiChang Hill Tin Industry Co., Ltd.||CID002844||CHINA|
|Tin||Jiangxi New Nanshan Technology Ltd.||CID001231||CHINA|
|Tin||Luna Smelter, Ltd.||CID003387||RWANDA|
|Tin||Maanshan Weitai Tin Co., Ltd.||CID003379||CHINA|
|Tin||Magnus 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||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||Pongpipat Company Limited||CID003208||MYANMAR|
|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 Babel Surya Alam Lestari||CID001406||INDONESIA|
|Tin||PT Bangka Serumpun||CID003205||INDONESIA|
|Tin||PT Bukit Timah||CID001428||INDONESIA|
|Tin||PT Menara Cipta Mulia||CID002835||INDONESIA|
|Tin||PT Mitra Stania Prima||CID001453||INDONESIA|
|Tin||PT Mitra Sukses Globalindo||CID003449||INDONESIA|
|Tin||PT Prima Timah Utama||CID001458||INDONESIA|
|Tin||PT Rajawali Rimba Perkasa||CID003381||INDONESIA|
|Tin||PT Refined Bangka Tin||CID001460||INDONESIA|
|Tin||PT Stanindo Inti Perkasa||CID001468||INDONESIA|
|Tin||PT Sukses Inti Makmur||CID002816||INDONESIA|
|Tin||PT Timah Nusantara||CID001486||INDONESIA|
|Tin||PT Timah Tbk Kundur||CID001477||INDONESIA|
|Tin||PT Timah Tbk Mentok||CID001482||INDONESIA|
|Tin||PT Tinindo Inter Nusa||CID001490||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||Tin Smelting Branch of Yunnan Tin Co., Ltd.||CID002180||CHINA|
|Tin||Tin Technology & Refining||CID003325||UNITED STATES OF AMERICA|
|Tin||White Solder Metalurgia e Mineracao Ltda.||CID002036||BRAZIL|
|Yunnan Chengfeng Non-ferrous Metals Co., Ltd.||CID002158||CHINA|
|Tin||Yunnan Yunfan Non-ferrous Metals Co., Ltd.||CID003397||CHINA|
|Tungsten||ACL Metais Eireli||CID002833||BRAZIL|
|Tungsten||Asia Tungsten Products Vietnam Ltd.||CID002502||VIET NAM|
|Tungsten||Chenzhou Diamond Tungsten Products Co., Ltd.||CID002513||CHINA|
|Tungsten||China Molybdenum Tungsten Co., Ltd.||CID002641||CHINA|
|Tungsten||Chongyi Zhangyuan Tungsten Co., Ltd.||CID000258||CHINA|
|Tungsten||Fujian Ganmin RareMetal Co., Ltd.||CID003401||CHINA|
|Tungsten||Ganzhou Haichuang Tungsten Co., Ltd.||CID002645||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 Tungsten GmbH||CID002541||GERMANY|
|Tungsten||Hunan Chenzhou Mining Co., Ltd.||CID000766||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||Lianyou Metals Co., Ltd.||CID003407||TAIWAN, PROVINCE OF CHINA|
|Tungsten||Malipo Haiyu Tungsten Co., Ltd.||CID002319||CHINA|
|Tungsten||Masan High-Tech Materials||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||TANIOBIS Smelting GmbH & Co. KG||CID002542||GERMANY|
|Tungsten||Unecha Refractory metals plant||CID002724||RUSSIAN FEDERATION|
|Tungsten||Wolfram Bergbau und Hutten AG||CID002044||AUSTRIA|
|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|
Table 3: Potential Countries of Origin for SORs Identified for the Reporting Period
Countries from which the 3TG used in Qorvos products may have originated based on the RMIs RCOI report dated March 25, 2022.
|Algeria||Grenada||Papua New Guinea|
|Antigua and Barbuda||Guinea||Poland|
|Bangladesh||Indonesia||Saint Kitts and Nevis|
|Bolivia (Plurinational State of)||Japan||Sierra Leone|
|Burkina Faso||Korea, Republic of||Slovenia|
|Chile||Lebanon||St Vincent and Grenadines|
|Congo, Democratic Republic of the*||Liechtenstein||Swaziland|
|Cuba**||Macao||Taiwan, Province of China|
|Denmark||Malta||Trinidad and Tobago|
|Ecuador||Monaco||Turks and Caicos|
|Eritrea||Mozambique||United Arab Emirates|
|Ethiopia||Namibia||United States of America|
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.
INDEPENDENT PRIVATE SECTOR AUDIT
Qorvo engaged RCS Global Ltd to conduct an independent private sector audit of this CMR for the Reporting Period. Refer to the audit report attached as Exhibit A to this CMR.
2022 PLANNED IMPROVEMENTS
Qorvo is committed to the responsible sourcing of 3TG and will continue to advance the implementation of its responsible mineral program with relevant suppliers.
For the 2022 reporting period, we plan to:
Continue working with suppliers who may provide incomplete or inaccurate sourcing information and drive them towards 100% identification of the actual SORs in the supply chain.
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, 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.
INDEPENDENT AUDITORS REPORT
INDEPENDENT PRIVATE SECTOR AUDIT REPORT
DODD FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT, SECTION 1502
To the Board of Directors
RCS Global Ltd (or RCS) conducted an Independent Private Sector Audit (IPSA) of Qorvo, Inc. (the Company) Conflict Minerals Report for the reporting period of January 1 to December 31, 2021. 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 Companys due diligence measures as set forth in the Companys Conflict Minerals Report for the reporting period from January 1 to December 31, 2021, 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 Companys 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, 2021, is consistent with the due diligence process that the Company undertook.
Management is responsible for the design of the Companys due diligence framework and the description of the Companys 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 auditors opinion on:
The consistency of the due diligence measures that the Company performed with either the design of the Companys due diligence framework or the OECD Due Diligence Guidance.
The completeness of the Companys description of the due diligence measures performed.
The suitability of the design or operating effectiveness of the Companys due diligence process.
Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance.
The Companys reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof.
The Companys 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 Companys due diligence framework and the Companys 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.
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 Companys due diligence framework for the reporting period from January 1 to December 31, 2021, as set forth in the Conflict Minerals Report is in conformity with, in all material respects, the OECD Guidance, and
The Companys 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, 2021, is consistent with the due diligence process that the Company undertook.
RCS Global Ltd
London, 06 April 2022