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Form SD QUICKLOGIC CORPORATION

May 27, 2016 12:55 PM EDT


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
QuickLogic Corporation
(Exact name of registrant as specified in its charter)
 
 
 
 
 
Delaware
 
000-22671
 
77-0188504
(State or other jurisdiction
of incorporation)
 
(Commission
File Number)
 
(IRS Employer
Identification No.)
 
1277 Orleans Drive, Sunnyvale, CA
 
 
 
94089-1138
(Address of principal executive offices)
 
 
 
(Zip Code)

1277 Orleans Drive
Sunnyvale, CA 94089
(Address of principal executive offices) (Zip Code)
Suping (Sue) Cheung
Principal Accounting Officer and Corporate Controller
(408) 990-4000
(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:
 
ý
Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2015 to December 31, 2015.

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Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Conflict Minerals Report (the “Report”) of QuickLogic Corporation (“QuickLogic” or the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2015 to December 31, 2015 and attached as Exhibit 1.01 to this Form SD.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals referred to as “Conflict Minerals” are gold, columbite-tantalite (coltan), cassiterite and wolfamite, including their derivatives which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and our Report are the Democratic Republic of Congo (the “DRC”), the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

We develop and market low power customizable semiconductor solutions that enable Original Equipment Manufacturers ("OEMs") to maximize battery life for highly differentiated, immersive user experiences with Smartphone, Wearable, Tablet and Internet-of-Things devices. We deliver these benefits through industry leading ultra-low power customer programmable System on Chip ("SoC") semiconductor solutions, embedded software, and algorithm solutions for always-on voice and sensor processing, and enhanced visual experiences. We are a fabless semiconductor company that provides comprehensive, flexible sensor processing solutions, ultra-low power display bridges, and ultra-low power Field Programmable Gate Arrays, or FPGAs. As a semiconductor company, we have concluded that Conflict Minerals are necessary to the functionality or production of our products.
Our products are manufactured by our industry recognized suppliers in accordance with our specifications. As detailed in our Report, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) reasonably designed to determine if any of these Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources. Our RCOI primarily consisted of submitting the Conflict Minerals Reporting Template (“CMRT”) prepared by the Conflict Free Sourcing Initiative (“CFSI”), an initiative of the Electronic Industry Citizenship Coalition and Global eSustainability Initiative (“EICC-GeSI”) to the first tier contract manufacturers of our devices in 2015. Responses were reviewed for completeness, reasonableness and consistency, and we routinely followed up with our contract manufacturers for corrections and clarifications. During 2015, we renewed our membership with CFSI, the industry initiative which audits the due diligence activities of smelters and refiners and we contracted with a third party vendor (Source Intelligence) to analyze the CMRTs provided to us. Through our membership in the CFSI, we receive their RCOI data which we also relied upon when reviewing the information provided to us by our first tier contract manufacturers.
We submitted this template to six contract manufacturers which represents 100% of our contract manufacturers. Of these responding contract manufacturers, 100% indicated one or more of the Conflict Minerals as necessary to the functionality or production of the products supplied.
Conflict Minerals Disclosure
This Form SD of the Company is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2015 to December 31, 2015.
A copy of the Company’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available at http://ir.quicklogic.com/sec.cfm.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, the Company is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.
Section 2 – Exhibits
The following exhibit is filed as part of this report.
Item 2.01 Exhibits.
Exhibit 1.01 – 2015 Conflict Minerals Report of QuickLogic Corporation as required by Items 1.01 and 1.02 of this Form.

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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
 
 
 
 
Date: May 27, 2016
 
QuickLogic Corporation
 
 
 
 
/s/ Suping (Sue) Cheung
 
 
 
 
 
Suping (Sue) Cheung
Principal Accounting Officer and Corporate Controller
 


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EXHIBIT INDEX
 
 
 
 
Exhibit
No.
  
Description
 
 
1.01
  
2015 Conflict Minerals Report of QuickLogic Corporation as required by Items 1.01 and 1.02 of this Form.


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Exhibit 1.01
Conflict Minerals Report
For The Reporting Period from January 1, 2015 to December 31, 2015
This Conflict Minerals Report (the “Report”) of QuickLogic Corporation (“QuickLogic” or the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2015 to December 31, 2015.

The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals referred to as “Conflict Minerals” are gold, columbite-tantalite (coltan), cassiterite and wolfamite, including their derivatives which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of Congo (the “DRC”), the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

Description of the Company's Products Covered by this Report

This Report relates to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by the Company; and (iii) for which the manufacture was completed during calendar year 2015.

These products, which are referred to in this Report collectively as the "Covered Products," are the following:

QuickLogic Product Platform Families
Description
ARCTICLINK®
Semiconductor device
ARCTICLINK II
Semiconductor device
ARCTICLINK III
Semiconductor device
ARCTICLINK 3 S1
Semiconductor device
ARCTICLINK 3 S2
Semiconductor device
ECLIPSE
Semiconductor device
ECLIPSE II
Semiconductor device
ECLIPSE PLUS
Semiconductor device
PASIC®3
Semiconductor device
POLARPRO®
Semiconductor device
POLARPRO II
Semiconductor device
POLARPRO 3
Semiconductor device
POLARPRO 3E
Semiconductor device
QUICKPCI
Semiconductor device
QUICKRAM
Semiconductor device
Description of the Company’s Reasonable Country of Origin Inquiry
As described in this Report, we have determined that the following Conflict Minerals, namely gold, tantalum, tin and tungsten, are necessary to the functionality or production of products contracted to be manufactured by us during the calendar year 2015. As a result, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) reasonably designed to determine if any of these Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources. Our supply chain is complex, and there are many third parties in the supply chain between the ultimate manufacturer of the Covered Products and the original sources of Conflict Minerals. The Company does not directly purchase Conflict Minerals from mines, smelters or refiners. Therefore, the Company must rely on the entities we contract to manufacture the Covered Products to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products. In designing our RCOI, we employed a combination of measures to determine whether the Conflict

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Minerals in our Covered Products originated from the Covered Countries, and determined that the Company would survey each of its first tier contract manufacturers.
As such, our RCOI primarily consisted of submitting the Conflict Minerals Reporting Template (“CMRT”) prepared by the Conflict Free Sourcing Initiative (“CFSI”), an initiative of the Electronic Industry Citizenship Coalition and Global eSustainability Initiative (“EICC-GeSI”) to the first tier contract manufacturers of our devices in 2015. Only CMRT’s 4.01or higher were accepted. Responses were reviewed for completeness, reasonableness and consistency, and routinely followed up for corrections and clarifications as needed. During 2015, we renewed our membership with CFSI, the industry initiative which audits the due diligence activities of smelters and refiners and we contracted with a third party vendor (Source Intelligence) to analyze the CMRTs provided to us. Through our membership in the CFSI, we receive their RCOI data which we also relied upon when reviewing the information provided to us by our first tier contract manufacturers.
We submitted this template to six contract manufacturers which represents 100% of our contract manufacturers. Of these responding contract manufacturers, 100% indicated one or more of the Conflict Minerals as necessary to the functionality or production of the products supplied.
Description of the Company’s Due Diligence Process
Based on this information, we performed additional due diligence on the source and chain of custody of these Conflict Minerals based on the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“Framework”) to determine if the Conflict Minerals that may have originated in the Covered Countries benefited armed groups. After performing the RCOI and due diligence in conformity with the Framework, we were unable to comprehensively determine the origin of all Conflict Minerals, the facilities used to process them, their country of origin and their mine or location of origin.
The Company's due diligence measures have been designed to conform to the framework in the Organization for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High Risk Areas: Second Edition, including the related supplements on gold, tin, tantalum and tungsten (the "OECD Guidance"). The OECD Guidance is an internationally recognized due diligence framework.
In accordance with the five-step OECD Guidance, the design of our due diligence includes, but is not limited to, the following five steps: (i) establishment of strong company management systems, (ii) identification and assessment of risks in the supply chain, (iii) designing and implementing a strategy to respond to identified risks, (iv) carrying out an independent third-party audit of smelter/refiner’s due diligence practices and (v) reporting on supply chain due diligence. A description of certain activities undertaken by us in respect of each of the five steps of the OECD Guidance is described below

1.
Establishment of Strong Company Management Systems
We have completed a number of steps to establish a management system for addressing the sourcing of Conflict Minerals in our Covered Products. These actions include:

a.
Adopt and Commit to a Supply Chain Policy for Conflict Minerals: Our Conflict Minerals Policy is available at http://www.quicklogic.com/corporate/support/conflict-minerals-policy. Our Policy underscores the Company’s commitment to ethical business conduct and the responsible sourcing of minerals and to working with our suppliers to ensure compliance with SEC regulations.

Our Policy notes the Company’s support of the industry-wide efforts the EICC-GeSI are making to address responsible sourcing of minerals through the development of the CFSI. Our policy discusses the Company’s adoption and use of the industry standard CMRT created by the EICC-GeSI to collect sourcing information related to conflict minerals as an element of our reasonable country of origin inquiry to verify the responsible sourcing of materials and to support compliance with SEC regulations.

b.
Internal Management to Support Supply Chain Due Diligence: Our Vice President of Operations and Environmental Compliance Specialist (the “Conflict Minerals Team”) participate in the design and execution of our conflict minerals program and cooperate to manage and support our supply chain due diligence. The Conflict Minerals Team identified the suppliers to be contacted and adopted and approved for use the Reporting Template discussed above. The Environmental Compliance Specialist interacts directly with our contract manufacturers and third party, Source Intelligence to obtain updated and current Reporting Templates and analyzes the information provided on the sourcing of the conflict minerals used in the manufacture of the Covered Products. Each response

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is reviewed to identify missing information and unclear responses. The Environmental Compliance Specialist meets regularly with the Vice President of Operations and Source Intelligence to discuss the results of the due diligence efforts and appropriate follow-up measures to be taken with our contract manufacturers. The Vice President of Operations reports on the status of the Company’s supply chain due diligence at regularly scheduled meetings of the Company’s Board of Directors.

c.
Controls and Transparency to Support Supply Chain Diligence: We use the CMRT to identify the smelters and refiners that are in the supply chain of each of our contract manufactures. We review and compare this list to the list of smelters and refiners identified by the CFSI to be active in the CFSI. This enables us to identify the smelters and refiners that have been determined to be conflict-free and those that are actively progressing towards an audit to determine their status. We use CFSI’s RCOI data to further verify the compliant smelter/refiners sourcing information as well as Source Intelligence’s database. We have determined that this approach represents the most reasonable effort we can make to determine whether the minerals used in the production of our Covered Products are conflict-free.

d.
Supplier Engagement: We are dependent upon our contract manufactures to manufacture the Covered Products. We continue to work with our contract manufacturers to support their efforts to identify the sources and status of the Conflict Minerals used in our Covered Products and to encourage each smelter and refiner in our supply chain to become an active participant in the CFSI. We continue to actively engage with our contract manufacturers to strengthen our relationship with them and we have communicated to our contract manufacturers our commitment to sourcing Conflict Minerals in a manner that does not benefit armed groups in the Covered Countries.

e.
Grievance Mechanism: We have grievance mechanisms in place that enable employees and suppliers to report violations of the Company’s policies. We have a compliance hotline which is operated by an independent company that may be called at any time to report grievances and invite individuals with grievances to bring these matters to the attention of the Audit Committee of our Board of Directors by written correspondence on a confidential basis. We also employ an email address by which matters may be brought at any time to the attention of our Conflict Minerals Team by sending an email to [email protected].

2.
Identification and Assessment of Risks in the Supply Chain

Because of our position within our supply chain, it is difficult for us to identify actors upstream from our first tier contract manufacturers. As discussed above, we identified each of our first tier contract manufacturers and we have relied upon them to provide us with the necessary information about the source of Conflict Minerals contained in the products they manufacture on our behalf. Our contract manufacturers are similarly reliant upon information provided by their suppliers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products.

We requested each of our contract manufacturers to complete the CMRT and review the sourcing information provided in response to our requests for accuracy and completeness. In the event we find the responses to the Reporting Template unclear or incomplete, we contact the contract manufacturer in question for additional information and clarification. We intend to contact each of our contract manufacturers at least once every six months to check on the status of their continuing due diligence and to obtain updated information. We record all information obtained from the Reporting Templates to identify the smelters and refiners in our supply chain. We compare the list of the smelters and refiners in our supply chain to the lists compiled by the CFSI to determine which smelters have been determined to be compliant with the CFSI assessment protocols.

3.
Designing and Implementing a Strategy to Respond to Identified Risks

In response to this risk assessment, the Company has an approved risk management plan which is implemented, managed and monitored through the above-described Conflict Minerals Team under the oversight of our Board of Directors. As noted above, we participate in the electronics industry’s EICC-GeSI Conflict Free Sourcing Initiative to identify smelters that provide material to our supply chain and to determine whether these smelters are compliant with the CFSI assessment protocols. We support the continued efforts of the EICC-GeSI to complete the audits of smelters that have agreed to date to participate in the CFSI and to encourage other identified smelters to become participants in the CFSI.

As a continuing part of our risk management plan, we have communicated our commitment to the use of conflict-free minerals in the manufacture of our Covered Products and our expectation that the manufacture of our Covered Products will be conflict-free.


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4.
Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain

We do not have a direct relationship with any smelters or refiners in our supply chain and, as a result, we do not directly conduct audits. Instead, we supported the development and implementation of independent third party audits of smelters such as the CFSI by encouraging our contract manufacturers and component suppliers to purchase materials from audited, conflict-free smelters and determine whether the smelters that were used to process these minerals were validated as conflict-free as part of the CFSI.

5.
Reporting on Supply Chain Due Diligence

In 2016, we publicly filed the Form SD and this Report with the SEC, and a copy of this Report and the Form SD are publicly available at http://ir.quicklogic.com/sec.cfm.

This Report includes information about the RCOI methodology utilized by the Company, the design of our due diligence process in conformance with the OECD Guidelines, the list of known smelters utilized in our supply chain identified in our due diligence process and a description of our products that incorporate conflict minerals necessary to the functionality or production of such products.
Findings
Based on the information that was provided by the Company’s contract manufacturers and otherwise obtained through the due diligence process, the Company believes that, to the extent reasonably determinable by the Company, the facilities that were used to process the Conflict Minerals contained in the Covered Products include the smelters and refiners listed below. Included is whether such smelters have received a “conflict free” designation by the CFSI as of May 27, 2016.
 
Smelter ID
CFSI
Country
GOLD
 
 
 
Aida Chemical Industries Co., Ltd.
CID000019
CF
Japan
Allgemeine Gold-und Silberscheideanstalt A.G.
CID000035
CF
Germany
AngloGold Ashanti Córrego do Sítio Mineração
CID000058
CF
Brazil
Argor-Heraeus SA
CID000077
CF
Switzerland
Asahi Pretec Corporation
CID000082
CF
Japan
Asahi Refining Canada Limited
CID000924
CF
Canada
Asahi Refining USA Inc.
CID000920
CF
United States
Asaka Riken Co., Ltd.
CID000090
CF
Japan
Aurubis AG
CID000113
CF
Germany
CCR Refinery - Glencore Canada Corporation
CID000185
CF
Canada
Chimet S.p.A.
CID000233
CF
Italy
Dowa
CID000401
CF
Japan
Eco-System Recycling Co., Ltd.
CID000425
CF
Japan
Elemetal Refining, LLC
CID001322
CF
United States
Heimerle + Meule GmbH
CID000694
CF
Germany
Heraeus Ltd. Hong Kong
CID000707
CF
China
Heraeus Precious Metals GmbH & Co. KG
CID000711
CF
Germany
Ishifuku Metal Industry Co., Ltd.
CID000807
CF
Japan
JX Nippon Mining & Metals Co., Ltd.
CID000937
CF
Japan
Kennecott Utah Copper LLC
CID000969
CF
United States
Kojima Chemicals Co., Ltd.
CID000981
CF
Japan
LS-NIKKO Copper Inc.
CID001078
CF
Republic of Korea
Materion
CID001113
CF
United States
Matsuda Sangyo Co., Ltd.
CID001119
CF
Japan
Metalor Technologies (Hong Kong) Ltd.
CID001149
CF
China
Metalor Technologies SA
CID001153
CF
Switzerland

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Metalor USA Refining Corporation
CID001157
CF
United States
Mitsubishi Materials Corporation
CID001188
CF
Japan
Mitsui Mining and Smelting Co., Ltd.
CID001193
CF
Japan
Nihon Material Co., Ltd.
CID001259
CF
Japan
Ohura Precious Metal Industry Co., Ltd.
CID001325
CF
Japan
PAMP SA
CID001352
CF
Switzerland
Rand Refinery (Pty) Ltd.
CID001512
CF
South Africa
Republic Metals Corporation
CID002510
CF
United States
Royal Canadian Mint
CID001534
CF
Canada
SEMPSA Joyería Platería SA
CID001585
CF
Spain
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CID001622
CF
China
Solar Applied Materials Technology Corp.
CID001761
CF
Taiwan
Sumitomo Metal Mining Co., Ltd.
CID001798
CF
Japan
Tanaka Kikinzoku Kogyo K.K.
CID001875
CF
Japan
The Refinery of Shandong Gold Mining Co., Ltd.
CID001916
CF
China
Tokuriki Honten Co., Ltd.
CID001938
CF
Japan
Umicore SA Business Unit Precious Metals Refining
CID001980
CF
Belgium
United Precious Metal Refining, Inc.
CID001993
CF
United States
Valcambi SA
CID002003
CF
Switzerland
Western Australian Mint trading as The Perth Mint
CID002030
CF
Australia
Yamamoto Precious Metal Co., Ltd.
CID002100
CF
Japan
Yokohama Metal Co., Ltd.
CID002129
CF
Japan
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CID002224
CF
China
TANTALUM
 
 
 
Changsha South Tantalum Niobium Co., Ltd.
CID000211
CF
China
F & X Electro-Materials Limited
CID000460
CF
China
Global Advanced Metals Boyertown
CID002557
CF
United States
H.C. Starck Co., Ltd.
CID002544
CF
Thailand
H.C. Starck GmbH Goslar
CID002545
CF
Germany
H.C. Starck GmbH Laufenburg
CID002546
CF
Germany
H.C. Starck Hermsdorf GmbH
CID002547
CF
Germany
H.C. Starck Inc.
CID002548
CF
United States
H.C. Starck Ltd.
CID002549
CF
Japan
H.C. Starck Smelting GmbH & Co.KG
CID002550
CF
Germany
Jiujiang Tanbre Co., Ltd.
CID000917
CF
China
Mitsu Mining & Smelting
CID001192
CF
Japan
Ningxia Orient Tantalum Industry Co., Ltd.
CID001277
CF
China
Plansee SE Liezen
CID002540
CF
Austria
Solikamsk Magnesium Works OAO
CID001769
CF
Russian Federation
Taki Chemicals
CID001869
CF
Japan
TIN
 
 
 
Alpha
CID000292
CF
United States
An Vinh Joint Stock Mineral Processing Company
CID002703
AU
Viet Nam
China Tin Group Co., Ltd.
CID001070
CF
China
Cooperativa Metalurgica de Rondônia Ltda.
CID000295
CF
Brazil
CV Serumpun Sebalai
CID000313
CF
Indonesia
CV United Smelting
CID000315
CF
Indonesia
Cooper Santa
CID000295
CF
Brazil
Dowa
CID000402
CF
Japan
Elmet S.L.U. (Metallo Group)
CID002774
CF
Spain

5                            



EM Vinto
CID000438
CF
Bolivia
Fenix Metals
CID000468
CF
Poland
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CID000538
CF
China
Magnu's Minerais Metais e Ligas Ltda.
CID002468
CF
Brazil
Malaysia Smelting Corporation (MSC)
CID001105
CF
Malaysia
Metallo-Chimique N.V.
CID002773
CF
Belgium
Mineração Taboca S.A.
CID001173
CF
Brazil
Minsur
CID001182
CF
Peru
Mitsubishi Materials Corporation
CID001191
CF
Japan
O.M. Manufacturing Philippines, Inc.
CID002517
CF
Philippines
Operaciones Meralurgical S.A.
CID001337
CF
Bolivia
PT Aries Kencana Sejahtera
CID000309
CF
Indonesia
PT Artha Cipta Langgeng
CID001399
CF
Indonesia
PT Babel Inti Perkasa
CID001402
CF
Indonesia
PT Bangka Tin Industry
CID001419
CF
Indonesia
PT Belitung Industri Sejahtera
CID001421
CF
Indonesia
PT BilliTin Makmur Lestari
CID001424
CF
Indonesia
PT Bukit Timah
CID001428
CF
Indonesia
PT DS Jaya Abadi
CID001434
CF
Indonesia
PT Eunindo Usaha Mandiri
CID001438
CF
Indonesia
PT Inti Stania Prima
CID002530
CF
Indonesia
PT JusTindo
CID000307
CF
Indonesia
PT Mitra Stania Prima
CID001453
CF
Indonesia
PT Panca Mega Persada
CID001457
CF
Indonesia
PT Prima Timah Utama
CID001458
CF
Indonesia
PT Refined Bangka Tin
CID001460
CF
Indonesia
PT Sariwiguna Binasentosa
CID001463
CF
Indonesia
PT Stanindo Inti Perkasa
CID001468
CF
Indonesia
PT Tambang Timah
CID001477
CF
Indonesia
PT Timah (Persero), Tbk
CID001482
CF
Indonesia
PT Tinindo Inter Nusa
CID001490
CF
Indonesia
PT Wahana Perkit Jaya
CID002479
CF
Indonesia
Rui Da Hung
CID001539
CF
Taiwan
Soft Metais Ltda.
CID001758
CF
Brazil
Thaisarco
CID001898
CF
Thailand
Toboca/ Paranapenema
CID001173
CF
Brazil
White Solder Metalurgia e Mineração Ltda.
CID002036
CF
Brazil
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CID002158
AU
China
Yunnan Tin Company, Ltd.
CID002180
CF
China
TUNGSTEN
 
 
 
A.L.M.T. Tungsten Corp.
CID000004
CF
Japan
Chongyi Zhangyuan Tungsten Co Ltd
CID000258
CF
China
Ganzhou Huaxin Tungsten Products
CID000875
CF
China
Ganzhou Seadragon W & Mo Co., Ltd.
CID002494
CF
China
Global Tungsten & Powders Corp.
CID000568
CF
United States
Guangdong Xianglu Tungsten Co., Ltd.
CID000218
CF
China
H.C. Starck GmbH
CID002541
CF
Germany
Hunan Chunchang Nonferrous Metals Co., Ltd
CID000769
CF
China
Japan New Metals Co., Ltd.
CID000825
CF
Japan
Kennametal Huntsville
CID000105
CF
United States

6                            



Tejing (Vietnam) Tungsten Co., Ltd.
CID001889
CF
Viet Nam
Wolfram Bergbau und Hütten AG
CID002044
CF
Austria
Xiamen Tungsten (H.C.) Co., Ltd.
CID002320
CF
China
Xiamen Tungsten Co., Ltd.
CID002082
CF
China
Countries of origin that these facilities may process conflict minerals include: Angola, Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Burundi, Cambodia, Canada, Central African Republic, Chile, China, Colombia, Côte D'Ivoire, Czech Republic, Djibouti, Ecuador, Ecuador, Egypt, Estonia, Ethiopia, France, Germany, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Laos, Luxembourg, Madagascar, Malaysia, Mongolia, Mozambique, Myanmar, Namibia, Netherlands, Nigeria, Peru, Portugal, Republic of Congo, Russia, Rwanda, Sierra Leone, Singapore, Slovakia, South Africa, South Korea, South Sudan, Spain, Suriname, Switzerland, Taiwan, Tanzania, Thailand, Uganda, United Kingdom, United States of America, Vietnam, Zambia, Zimbabwe

“CF” indicates that as of March 29, 2016, the smelter participates in the CFSI and has been certified and audited by the CFSI.
“AU” indicates that the smelter has agreed to participate in the CFSI, but that as of May 27, 2016, the audit process has not yet been completed.
Future Steps
We have communicated our expectations, as reflected in our Conflict Minerals Policy, to our contract manufacturers and other suppliers. Since the end of 2015, we have continued to engage with our first-tier suppliers to update their information on the source and chain of custody of conflict minerals in our supply chain and to require that all smelters utilized agree to participate in the CFSI.



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