Form SD CONTROL4 CORP
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Control4 Corporation
(Exact name of registrant as specified in its charter)
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Delaware |
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001-36017 |
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42-1583209 |
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(State or other jurisdiction |
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(Commission File Number) |
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(I.R.S. Employer |
11734 S. Election Road
Salt Lake City, Utah, 84020
(Address of principal executive offices) (Zip Code)
Joshua D. Ellis
General Counsel and Corporate Secretary
(801) 523-3100
(Name and telephone number, including area code, of 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, 2018 to December 31, 2018.
Section 1 — Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Form SD of Control4 Corporation (the “Company”) is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934 for the reporting period January 1, 2018 to December 31, 2018. A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 hereto and is publicly available on the Company’s website along with our Conflict Minerals Policy at: https://www.control4.com/legal/conflict-minerals-policy.
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
Item 2.01 Exhibits
The following exhibit is filed as part of this report:
Exhibit 1.01 — Conflict Minerals Report for the reporting period January 1, 2018 to December 31, 2018.
EXHIBIT INDEX
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Exhibit |
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Description |
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1.01 |
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Conflict Minerals Report for the reporting period January 1, 2018 to December 31, 2018. |
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.
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CONTROL4 CORPORATION. |
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By: |
/s/ Joshua D. Ellis |
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Joshua D. Ellis |
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General Counsel and Corporate Secretary |
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Date: May 31, 2019 |
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CONFLICT MINERALS REPORT OF CONTROL4 CORPORATION
FOR THE REPORTING PERIOD FROM JANUARY 1, 2018 TO DECEMBER 31, 2018
Background
This Conflict Minerals Report of Control4 Corporation (“Control4”) has been prepared pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (17 CFR 240.13p-1) (the “Rule”) promulgated by the Securities and Exchange Commission (“SEC”) to implement reporting and disclosure requirements related to how companies source certain minerals as directed by the Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank Act”).
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. These specified minerals, which we collectively refer to in this Report as the “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, namely tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo and adjoining countries, namely the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
If Conflict Minerals are necessary to the functionality or production of products manufactured or contracted to be manufactured by a company, the company is required to conduct a good faith reasonable country of origin inquiry (“RCOI”) to determine whether any of the necessary Conflict Minerals in those products originated in the Covered Countries and whether any of the necessary Conflict Minerals may be from recycled or scrap sources. If, as a result of the RCOI, a company knows or has reason to believe that any of the necessary Conflict Minerals in its supply chain may have originated in the Covered Countries, and may not be from recycled or scrap sources, then the company must perform due diligence on the Conflict Minerals’ source and chain of custody.
Company Overview
Control4 is a leading provider of smart home and business solutions that are designed to personalize and enhance how consumers engage with an ever-changing connected world. Our entertainment, smart lighting, comfort and convenience, security, and networking solutions unlock the potential of connected devices, and are designed to make entertainment systems easier to use and more accessible, homes and businesses more comfortable and energy efficient, networking more robust, and individuals more connected and secure. Our premium smart home and small business solutions provide consumers with the ability to integrate audio, video, lighting, temperature, security, communications, network management and other functionalities into a unified automation solution, customized to match their lifestyles and business needs. Our advanced software, delivered through our controller and user-interface products together with various cloud services, power this customized experience, enabling cohesive interoperability with thousands of connected Control4 and third-party devices.
Description of the Products Covered by this Report
This Report relates to Control4’s products: (i) for which Conflict Minerals are necessary to the functionality or production of the products; (ii) that were contracted to be manufactured by Control4; and (iii) for which the manufacture was completed during calendar year 2018. These products, which are referred to in this Report collectively as the “Covered Products,” include the following:
· Controllers: These devices contain Control4’s proprietary software that serves as a central hub to connect and control connected Control4 and third-party devices throughout the home. Our controllers use a ZigBee transceiver and a WiFi transceiver to interface to the home network.
· Interfaces: Interface products include remote controls, touch screens and door station units.
· Audio/Visual Products: Audio/Visual products are designed to deliver audio and video to multiple rooms within a home automation system, and include amplifiers, audio matrix switches, and speakers.
· Lighting: Lighting products include dimmers, relays, switches and configurable keypads and allow lighting control and automation throughout the home. Our keypad and controls switches may also be used for other functions such as garage doors, etc.
· Climate Control: Climate control products include thermostats, automatic blinds and fireplace switches and integrate existing heating and cooling systems with the home automation system.
· Networking: Networking products include wireless routers, switches and access points.
Supply Chain Overview
Control4 does not directly manufacture any of its Covered Products, but instead it relies on contract manufacturers to fabricate its products and their components. Thus, Control4 is completely removed from the sourcing and mining of Conflict Minerals. We do not purchase the Conflict Minerals directly from mines, smelters, or refiners. Control4’s supply chain with respect to the Covered Products is complex, and there are many third parties in the supply chain between the ultimate manufacture of the Covered Products and the original sources of the Conflict Minerals that are used to make the Covered Products’ component parts. Therefore, we must rely on our contract manufacturers and suppliers to provide information regarding the origin of the Conflict Minerals in the Covered Products as explained in greater detail below.
Reasonable Country-of-Origin Inquiry and Due Diligence Performed
Control4 has conducted a good faith RCOI regarding the Conflict Minerals that was designed to determine whether any of the Conflict Minerals in the Covered Products originated in the Covered Countries and/or whether any of the Conflict Minerals may be from recycled or scrap sources. In order to conduct this RCOI, Control4 identified the suppliers providing products and components that may contain Conflict Minerals (the “Identified Suppliers”), and requested that each Identified Supplier complete and return the Conflict Minerals Reporting Template (“Template”) created by the Responsible Minerals Initiative (“RMI”), an initiative founded by members of the Responsible Business Alliance and the Global e-Sustainability Initiative, which provides a standardized method for companies to collect representations, statements and data from their suppliers related to the presence, use, source and chain of custody of the Conflict Minerals. As a result of the RCOI, Control4 has reason to believe that a portion of the Conflict Minerals in its Covered Products may have originated in the “Covered Countries” and that these necessary Conflict Minerals may not be from recycled or scrap sources, so Control4 also performed due diligence on the source and chain of custody of the necessary Conflict Minerals. Control4 designed its due diligence process based on the due diligence framework in The Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, (the “OECD Framework”), taking into account Control4’s distance in the supply chain from the direct procurement of Conflict Minerals. We describe our due diligence process in greater detail below.
Description of Due Diligence Measures
Control4 integrated OECD’s Five-Step Framework into its due diligence measures as described below.
1. Establish Strong Company Management Systems
Control4 has a policy regarding Conflict Minerals that outlines its commitment to promote responsible sourcing practices and to promote the use of conflict-free minerals in our supply chain (the “Conflict Minerals Policy”). This policy is available on our website at http://www.control4.com/legal/conflict-minerals-policy. Control4 formed a cross-organizational committee (the “Committee”) to help us comply with our obligations under the Rule. The Committee includes representatives from our finance, legal, and supply chain teams. The Committee met periodically over the course of 2018 and the first part of 2019 to review Control4’s supply chain with respect to our use of components containing Conflict Minerals in 2018. Members of Control4’s executive team have oversight authority for the work done by the Committee.
Committee members reviewed the Rule, the OECD Framework, and various other supplementary materials provided by third parties, including the Conflict-Free Smelter & Refiners information provided by RMI. The Committee was responsible for communicating with our suppliers in order to encourage reporting, including completing and returning the Template created by RMI. In addition, Control4
established an internal electronic database for maintenance of business records relating to Conflict Minerals due diligence, including supplier responses to our inquiries, as well as spreadsheets containing aggregate data and analysis.
If any investor has any concern about Control4’s Conflict Minerals Policy, they may contact Control4’s board of directors in the manner described at http://investor.control4.com/directors.cfm.
2. Identify and Assess Risk in the Supply Chain
As mentioned above, as the first step in the good faith RCOI and due diligence processes, Control4 identified the suppliers providing products and components that may contain Conflict Minerals (the “Identified Suppliers”), which excluded packaging suppliers and suppliers of other products which do not contain any components that could contain Conflict Minerals. We then sent a letter to each of our Identified Suppliers communicating Control4’s commitment to sourcing responsibly and outlining our expectation that they do the same.
Control4 requested that each Identified Supplier complete and return the Conflict Minerals Reporting Template, which provides a standardized method for companies to collect representations, statements and data from their suppliers related to the presence, use, source and chain of custody of the Conflict Mineral. We requested our Identified Suppliers to use the Template to identify the smelters and refiners in the supply chain, as well as the country and mine of origin, of the Conflict Minerals used in our Covered Products. To help suppliers understand Control4’s expectations, and to facilitate supplier responsiveness to Control4’s inquiry, Control4 provided detailed instructions on completing the Template with specific references to the information that we need to see in the Template.
A total of 104 out of 234 suppliers were classified as Identified Suppliers and were contacted as part of the due diligence process. Out of 104 Identified Suppliers, Control4 has received responses from 68 of the Identified Suppliers. In instances where an Identified Supplier failed to return a completed Template, committee members had follow-up discussions and/or sent repeat requests to insist on completion of the Template. Even after providing our suppliers with explanatory materials, instructions and/or follow-up, in a number of instances our suppliers failed to adequately respond and Control4 received incomplete information regarding the facilities utilized to process necessary Conflict Minerals in supplier parts, as well as insufficient information regarding the mines or sources of origin of those Conflict Minerals. Some Identified Suppliers continued to respond generally on a company-wide basis when a more tailored response would have been more appropriate.
Control4 has not conducted its own supply chain audits, but rather, has relied on the information provided by the Responsible Minerals Assurance Process (“RMAP”) developed by the RMI to help assess the due diligence conducted by the identified smelters and refiners and to assess or verify their conformant status. The RMAP identifies smelters and refiners that an independent third-party audit has confirmed comply with the RMAP’s assessment protocols to assure sourcing of only conflict-free minerals. In particular, we compared the smelters and refiners used by our Identified Suppliers against the list of smelter and refinery facilities that received a “conformant” designation through the RMAP.
3. Design and Implement a Strategy to Respond to Risk
Through its Conflict Minerals Policy, contractual provisions in our supplier agreements requiring that our suppliers comply with all applicable conflict mineral laws, and interaction with its Identified Suppliers, Control4 encourages its Identified Suppliers to promote responsible sourcing practices for any Conflict Minerals used in our Covered Products. Control4 determines on a case-by-case basis the appropriate risk mitigation strategy for any supply chain risks identified in the course of its due diligence efforts. Potential outcomes typically include continuing to work with the supplier while identified risks are addressed, but could also include looking for alternative sources and restricting or terminating our relationship with the supplier. As we assess these relationships, we also take additional factors into consideration including supplier size and capabilities, whether alternatives are reasonable and economically available, transition costs and Control4’s dependence on the Identified Supplier.
4. Independent Third-Party Audit of Smelter/Refiner’s Due Diligence Practices
Control4 does not have any direct relationships with any smelters or refiners in its supply chain, and it did not perform or direct audits of any entity within its supply chain. As an alternative, the Company has relied on publicly available information, including principally information provided by the RMAP, an independent third-party audit program.
5. Report on Supply Chain Due Diligence
As required under the Rule, Control4 has timely filed our Form SD with the SEC for the 2018 Reporting Period, which contains this Report as an exhibit, and we have posted this Report on our website, see a link to this document on our Conflict Minerals Policy page at https://www.control4.com/legal/conflict-minerals-policy.
Due Diligence Outcome
Based on the information gathered in connection with our due diligence efforts, given that not all smelters identified by our Identified Suppliers were certified as “conformant” by the RMAP and that a number of Identified Supplier responses regarding the sources of raw materials for the Covered Products were determined to be uncertain, or unknown, overbroad, incomplete, or potentially inclusive of Covered Countries, Control4 cannot conclude that Conflict Minerals in Covered Products did not finance or benefit, directly or indirectly, armed groups in the Covered Countries.
The statements above are based on the RCOI process and due diligence performed in good faith by Control4 as described above, but as noted, Control4 is a downstream entity, and does not purchase Conflict Minerals directly from mines, smelters or refiners. Tracing these minerals to their sources is a challenge that requires Control4 to rely on its Identified Suppliers in its efforts to achieve supply chain transparency. A number of factors could introduce errors or otherwise affect this Report. These factors include, but are
not limited to, incomplete supplier, product or product content information, gaps in Identified Suppliers’ data, gaps in smelter data, errors or omissions by Identified Suppliers in their reporting, failure to accurately identify all Identified Suppliers and the appropriate persons to contact at each Identified Supplier, errors or omissions by smelters, gaps in supplier education and knowledge, lack of timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the protocol, oversights or errors in conflict-free smelter audits, Covered Countries sourced materials being declared secondary materials, and smuggling of the Conflict Minerals to countries beyond the Covered Countries.
Identified Smelters and Refiners
While some of Control4’s Identified Suppliers provided information for the particular products they supply to Control4, the majority provided this information on a company-wide basis. When the Identified Suppliers provided product-level information, Control4 has listed in Schedule 1 of this Report the smelters or refiners identified. However, with the exception of our largest supplier, Sanmina Corporation, which Control4 determined should also be included because of the large number of products they supply to Control4, when the Identified Suppliers provided only company-level information, Control4 determined that it did not have sufficient information to reasonably identify the particular smelter or refiner that processed the Conflict Minerals contained in the particular type of component in the Covered Products, and thus did not include the smelters or refiners in Schedule 1. In addition, the smelters and refiners listed on Schedule 1 include only those reported entities that were listed on the RMI Standard Smelter List tab of the Template with a current smelter identification number, because those are the only reported entities that Control4 was able to determine were bona fide smelters or refiners. Based solely on information provided by our Identified Suppliers and the RMAP, of the 309 smelters and refiners identified on Schedule 1, 165 have been certified as “conformant” by the RMAP. An additional 87 of the remaining smelters and refiners were previously certified as “conformant” but the certifications have subsequently expired, and 52 of these 87 are currently actively involved in the re-audit process. Furthermore, 4 additional smelters and refiners are actively under-going audits in the process of becoming certified as “conformant” by the RMAP for the first time or are participating in one of the cross recognized programs — LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification.
Identified Countries of Origin of Necessary Conflict Minerals
Where such information was provided, Control4 has listed in Schedule 2 of this Report the countries of origin of the Necessary Conflict Minerals provided to us in the Templates of Identified Suppliers which reported product-level information as well as Sanmina Corporation.
Future Due Diligence and Risk Mitigation
Control4 expects to take the following steps, among others, to continue to improve the due diligence conducted and to further mitigate the risk that the necessary Conflict Minerals in Control4’s products benefit armed groups in the Covered Countries, including:
1. The following facilities have been identified as being of highest concern to the supply chain:
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African Gold Refinery |
UGANDA |
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Universal Precious Metals Refining Zambia |
ZAMBIA |
These smelters are located in Covered Countries, list Covered Countries as sources of Conflict Minerals, and are not certified as conformant by the RMAP. These smelters were both listed by a single Identified Supplier that is also subject to the Dodd Frank Act and has adopted its own Conflict Minerals Policy in which it commits to take the required steps over time to source from socially responsible suppliers when the choice of supplier is within its control. As Control4 does not have a direct relationship with these smelters or refiners, but we will continue to encourage the Identified Supplier to further refine their due diligence and to responsibly source any Conflict Minerals used in Control4’s Covered Products.
2. Control4 intends to continue to work with all Identified Suppliers that provided incomplete or insufficient information, or were unresponsive to the information request, in an effort to obtain complete and accurate information. In addition, Control4 will continue to encourage any Identified Suppliers that identified any supply that potentially originated in the Covered Countries to work to ensure that all sources are certified as “conflict free.”
3. Control4 intends to reiterate its request that all Identified Suppliers complete the Template by providing product- or component-specific information and provide responses that identify materials down to the smelter and countries of origin of the Conflict Minerals.
4. Control4 was disappointed to see the percentage of identified smelters used by its third-party suppliers designated as compliant by the RMAP fall from 67% in 2017 to 53% in 2018, and this seems to have been driven, in large part, by the near doubling of the number of smelters that let their certifications expire. Control4 will consider initiating discussions with its suppliers asking them to survey any smelters that have let their certificates expire to determine why they did so and encourage them to continue to source from conflict-free sources.
Cautionary Note on Forward-looking Statements
This Report includes forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. All statements other than statements of historical fact contained in this Report are forward-looking statements, including without limitation, Control4’s ability to improve its Conflict Minerals due diligence processes and engage more productively with its current suppliers as well as any future suppliers. These forward-looking statements are made as of the date they were first issued, and were based on the then-current expectations, estimates, forecasts, and projections, as well as the beliefs and assumptions of
management. Forward-looking statements are subject to a number of risks and uncertainties, many of which involve factors or circumstances that are beyond Control4’s control. Control4’s actual actions or results could differ materially from those stated or implied in forward-looking statements due to a number of factors, including but not limited to, risks detailed in Control4’s most recent Annual Report on Form 10-K and subsequent reports filed with the Securities and Exchange Commission, as well as other documents that may be filed by the company from time to time with the Securities and Exchange Commission. Past performance is not necessarily indicative of future results. The forward-looking statements included in this Report represent Control4’s views as of the date this Report was filed with the SEC. Control4 anticipates that subsequent events and developments may cause its views to change. Control4 has no intention and undertakes no obligation to update or revise any forward-looking statements, whether as a result of new information, future events, or otherwise. These forward-looking statements should not be relied upon as representing Control4’s views as of any date subsequent to the date of filing of this Report.
Schedule 1
Smelter and Refiner Information
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Metal |
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Standard Smelter Name |
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Smelter Facility Location: Country |
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Gold |
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Advanced Chemical Company |
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UNITED STATES OF AMERICA |
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Gold |
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Aida Chemical Industries Co., Ltd. |
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JAPAN |
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Gold |
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Allgemeine Gold-und Silberscheideanstalt A.G. |
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GERMANY |
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Gold |
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Almalyk Mining and Metallurgical Complex (AMMC) |
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UZBEKISTAN |
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Gold |
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AngloGold Ashanti Corrego do Sitio Mineracao |
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BRAZIL |
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Gold |
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Argor-Heraeus S.A. |
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SWITZERLAND |
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Gold |
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Asahi Pretec Corp. |
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JAPAN |
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Gold |
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Asaka Riken Co., Ltd. |
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JAPAN |
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Gold |
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Aurubis AG |
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GERMANY |
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Gold |
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
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PHILIPPINES |
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Gold |
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Boliden AB |
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SWEDEN |
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Gold |
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C. Hafner GmbH + Co. KG |
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GERMANY |
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Gold |
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CCR Refinery - Glencore Canada Corporation |
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CANADA |
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Gold |
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Cendres + Metaux S.A. |
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SWITZERLAND |
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Gold |
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Chimet S.p.A. |
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ITALY |
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Gold |
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Daejin Indus Co., Ltd. |
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KOREA, REPUBLIC OF |
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Gold |
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DSC (Do Sung Corporation) |
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KOREA, REPUBLIC OF |
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Gold |
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DODUCO Contacts and Refining GmbH |
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GERMANY |
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Gold |
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Dowa |
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JAPAN |
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Gold |
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Eco-System Recycling Co., Ltd. |
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JAPAN |
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Gold |
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OJSC Novosibirsk Refinery |
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RUSSIAN FEDERATION |
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Gold |
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HeeSung Metal Ltd. |
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KOREA, REPUBLIC OF |
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Gold |
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Heimerle + Meule GmbH |
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GERMANY |
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Gold |
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Heraeus Metals Hong Kong Ltd. |
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CHINA |
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Gold |
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Heraeus Precious Metals GmbH & Co. KG |
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GERMANY |
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Gold |
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Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
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CHINA |
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Gold |
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Ishifuku Metal Industry Co., Ltd. |
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JAPAN |
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Gold |
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Istanbul Gold Refinery |
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TURKEY |
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Gold |
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Japan Mint |
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JAPAN |
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Gold |
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Jiangxi Copper Co., Ltd. |
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CHINA |
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Gold |
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Asahi Refining USA Inc. |
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UNITED STATES OF AMERICA |
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Gold |
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Asahi Refining Canada Ltd. |
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CANADA |
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Gold |
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JSC Uralelectromed |
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RUSSIAN FEDERATION |
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Gold |
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JX Nippon Mining & Metals Co., Ltd. |
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JAPAN |
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Gold |
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Kazzinc |
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KAZAKHSTAN |
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Gold |
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Kennecott Utah Copper LLC |
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UNITED STATES OF AMERICA |
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Gold |
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Kojima Chemicals Co., Ltd. |
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JAPAN |
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Gold |
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Kyrgyzaltyn JSC |
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KYRGYZSTAN |
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Gold |
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LS-NIKKO Copper Inc. |
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KOREA, REPUBLIC OF |
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Gold |
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Materion |
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UNITED STATES OF AMERICA |
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Gold |
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Matsuda Sangyo Co., Ltd. |
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JAPAN |
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Gold |
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Metalor Technologies (Suzhou) Ltd. |
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CHINA |
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Gold |
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Metalor Technologies (Hong Kong) Ltd. |
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CHINA |
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Gold |
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Metalor Technologies (Singapore) Pte., Ltd. |
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SINGAPORE |
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Gold |
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Metalor Technologies S.A. |
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SWITZERLAND |
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Gold |
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Metalor USA Refining Corporation |
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UNITED STATES OF AMERICA |
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Gold |
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Metalurgica Met-Mex Penoles S.A. De C.V. |
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MEXICO |
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Gold |
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Mitsubishi Materials Corporation |
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JAPAN |
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Gold |
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Mitsui Mining and Smelting Co., Ltd. |
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JAPAN |
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Gold |
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Moscow Special Alloys Processing Plant |
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RUSSIAN FEDERATION |
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Gold |
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Nadir Metal Rafineri San. Ve Tic. A.S. |
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TURKEY |
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Gold |
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Nihon Material Co., Ltd. |
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JAPAN |
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Gold |
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Ohura Precious Metal Industry Co., Ltd. |
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JAPAN |
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Gold |
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OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) |
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RUSSIAN FEDERATION |
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Gold |
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PAMP S.A. |
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SWITZERLAND |
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Gold |
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Prioksky Plant of Non-Ferrous Metals |
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RUSSIAN FEDERATION |
|
Gold |
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PT Aneka Tambang (Persero) Tbk |
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INDONESIA |
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Gold |
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PX Precinox S.A. |
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SWITZERLAND |
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Gold |
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Rand Refinery (Pty) Ltd. |
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SOUTH AFRICA |
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Gold |
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Royal Canadian Mint |
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CANADA |
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Gold |
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Samduck Precious Metals |
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KOREA, REPUBLIC OF |
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Gold |
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SEMPSA Joyeria Plateria S.A. |
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SPAIN |
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Gold |
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Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
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CHINA |
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Gold |
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Sichuan Tianze Precious Metals Co., Ltd. |
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CHINA |
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Gold |
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SOE Shyolkovsky Factory of Secondary Precious Metals |
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RUSSIAN FEDERATION |
|
Gold |
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Solar Applied Materials Technology Corp. |
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TAIWAN, PROVINCE OF CHINA |
|
Gold |
|
Sumitomo Metal Mining Co., Ltd. |
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JAPAN |
|
Gold |
|
Tanaka Kikinzoku Kogyo K.K. |
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JAPAN |
|
Gold |
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The Refinery of Shandong Gold Mining Co., Ltd. |
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CHINA |
|
Gold |
|
Tokuriki Honten Co., Ltd. |
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JAPAN |
|
Gold |
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Torecom |
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KOREA, REPUBLIC OF |
|
Gold |
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Umicore Brasil Ltda. |
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BRAZIL |
|
Gold |
|
Umicore S.A. Business Unit Precious Metals Refining |
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BELGIUM |
|
|
|
|
|
|
|
Gold |
|
United Precious Metal Refining, Inc. |
|
UNITED STATES OF AMERICA |
|
Gold |
|
Valcambi S.A. |
|
SWITZERLAND |
|
Gold |
|
Western Australian Mint (T/a The Perth Mint) |
|
AUSTRALIA |
|
Gold |
|
Yamakin Co., Ltd. |
|
JAPAN |
|
Gold |
|
Yokohama Metal Co., Ltd. |
|
JAPAN |
|
Gold |
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
|
CHINA |
|
Gold |
|
Gold Refinery of Zijin Mining Group Co., Ltd. |
|
CHINA |
|
Gold |
|
Guangdong Jinding Gold Limited |
|
CHINA |
|
Gold |
|
Umicore Precious Metals Thailand |
|
THAILAND |
|
Gold |
|
Geib Refining Corporation |
|
UNITED STATES OF AMERICA |
|
Gold |
|
MMTC-PAMP India Pvt., Ltd. |
|
INDIA |
|
Gold |
|
Singway Technology Co., Ltd. |
|
TAIWAN, PROVINCE OF CHINA |
|
Gold |
|
Al Etihad Gold Refinery DMCC |
|
UNITED ARAB EMIRATES |
|
Gold |
|
Emirates Gold DMCC |
|
UNITED ARAB EMIRATES |
|
Gold |
|
T.C.A S.p.A |
|
ITALY |
|
Gold |
|
REMONDIS PMR B.V. |
|
NETHERLANDS |
|
Gold |
|
Korea Zinc Co., Ltd. |
|
KOREA, REPUBLIC OF |
|
Gold |
|
Marsam Metals |
|
BRAZIL |
|
Gold |
|
SAAMP |
|
FRANCE |
|
Gold |
|
Italpreziosi |
|
ITALY |
|
Gold |
|
SAXONIA Edelmetalle GmbH |
|
GERMANY |
|
Gold |
|
WIELAND Edelmetalle GmbH |
|
GERMANY |
|
Gold |
|
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
|
AUSTRIA |
|
Gold |
|
AU Traders and Refiners |
|
SOUTH AFRICA |
|
Gold |
|
SungEel HiMetal Co., Ltd. |
|
KOREA, REPUBLIC OF |
|
Gold |
|
Planta Recuperadora de Metales SpA |
|
CHILE |
|
Gold |
|
Safimet S.p.A |
|
ITALY |
|
Gold |
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
|
CHINA |
|
Gold |
|
Abington Reldan Metals, LLC |
|
UNITED STATES OF AMERICA |
|
Gold |
|
African Gold Refinery |
|
UGANDA(1) |
|
Gold |
|
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
|
TURKEY |
|
Gold |
|
Bangalore Refinery |
|
INDIA |
|
Gold |
|
Caridad |
|
MEXICO |
|
Gold |
|
Chugai Mining |
|
JAPAN |
|
Gold |
|
Daye Non-Ferrous Metals Mining Ltd. |
|
CHINA |
|
Gold |
|
Degussa Sonne / Mond Goldhandel GmbH |
|
GERMANY |
|
Gold |
|
DS PRETECH Co., Ltd. |
|
KOREA, REPUBLIC OF |
|
Gold |
|
Fidelity Printers and Refiners Ltd. |
|
ZIMBABWE |
|
Gold |
|
GCC Gujrat Gold Centre Pvt. Ltd. |
|
INDIA |
|
Gold |
|
Great Wall Precious Metals Co., Ltd. of CBPM |
|
CHINA |
|
Gold |
|
Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
|
CHINA |
|
Gold |
|
Hangzhou Fuchunjiang Smelting Co., Ltd. |
|
CHINA |
|
Gold |
|
Hunan Chenzhou Mining Co., Ltd. |
|
CHINA |
|
Gold |
|
Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
|
CHINA |
|
Gold |
|
HwaSeong CJ CO., LTD. |
|
KOREA, REPUBLIC OF |
|
Gold |
|
JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
|
RUSSIAN FEDERATION |
|
Gold |
|
Kaloti Precious Metals |
|
UNITED ARAB EMIRATES |
|
Gold |
|
Kazakhmys Smelting LLC |
|
KAZAKHSTAN |
|
Gold |
|
KGHM Polska Miedz Spolka Akcyjna |
|
POLAND |
|
Gold |
|
Kyshtym Copper-Electrolytic Plant ZAO |
|
RUSSIAN FEDERATION |
|
Gold |
|
L’azurde Company For Jewelry |
|
SAUDI ARABIA |
|
Gold |
|
Lingbao Gold Co., Ltd. |
|
CHINA |
|
Gold |
|
L’Orfebre S.A. |
|
ANDORRA |
|
Gold |
|
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
|
CHINA |
|
Gold |
|
Modeltech Sdn Bhd |
|
MALAYSIA |
|
Gold |
|
Morris and Watson |
|
NEW ZEALAND |
|
Gold |
|
Morris and Watson Gold Coast |
|
AUSTRALIA |
|
Gold |
|
Navoi Mining and Metallurgical Combinat |
|
UZBEKISTAN |
|
Gold |
|
NH Recytech Company |
|
KOREA, REPUBLIC OF |
|
Gold |
|
Pease & Curren |
|
UNITED STATES OF AMERICA |
|
Gold |
|
Penglai Penggang Gold Industry Co., Ltd. |
|
CHINA |
|
Gold |
|
QG Refining, LLC |
|
UNITED STATES OF AMERICA |
|
Gold |
|
Refinery of Seemine Gold Co., Ltd. |
|
CHINA |
|
Gold |
|
Sabin Metal Corp. |
|
UNITED STATES OF AMERICA |
|
Gold |
|
SAFINA A.S. |
|
CZECH REPUBLIC |
|
Gold |
|
Sai Refinery |
|
INDIA |
|
Gold |
|
Samwon Metals Corp. |
|
KOREA, REPUBLIC OF |
|
Gold |
|
Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
|
CHINA |
|
Gold |
|
State Research Institute Center for Physical Sciences and Technology |
|
LITHUANIA |
|
Gold |
|
Sudan Gold Refinery |
|
SUDAN |
|
Gold |
|
Tongling Nonferrous Metals Group Co., Ltd. |
|
CHINA |
|
Gold |
|
Tony Goetz NV |
|
BELGIUM |
|
Gold |
|
TOO Tau-Ken-Altyn |
|
KAZAKHSTAN |
|
Gold |
|
Universal Precious Metals Refining Zambia |
|
ZAMBIA(1) |
|
Gold |
|
Yunnan Copper Industry Co., Ltd. |
|
CHINA |
|
Tantalum |
|
F&X Electro-Materials Ltd. |
|
CHINA |
|
Tantalum |
|
Ningxia Orient Tantalum Industry Co., Ltd. |
|
CHINA |
|
Tantalum |
|
H.C. Starck Tantalum and Niobium GmbH |
|
GERMANY |
|
Tantalum |
|
Changsha South Tantalum Niobium Co., Ltd. |
|
CHINA |
|
Tantalum |
|
Guangdong Rising Rare Metals-EO Materials Ltd. |
|
CHINA |
|
Tantalum |
|
Global Advanced Metals Boyertown |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
H.C. Starck Co., Ltd. |
|
THAILAND |
|
Tantalum |
|
H.C. Starck Hermsdorf GmbH |
|
GERMANY |
|
Tantalum |
|
H.C. Starck Inc. |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
H.C. Starck Ltd. |
|
JAPAN |
|
Tantalum |
|
Jiujiang Tanbre Co., Ltd. |
|
CHINA |
|
Tantalum |
|
Mitsui Mining and Smelting Co., Ltd. |
|
JAPAN |
|
Tantalum |
|
Solikamsk Magnesium Works OAO |
|
RUSSIAN FEDERATION |
|
Tantalum |
|
Taki Chemical Co., Ltd. |
|
JAPAN |
|
Tantalum |
|
Ulba Metallurgical Plant JSC |
|
KAZAKHSTAN |
|
Tantalum |
|
Exotech Inc. |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
Global Advanced Metals Aizu |
|
JAPAN |
|
Tantalum |
|
Guangdong Zhiyuan New Material Co., Ltd. |
|
CHINA |
|
Tantalum |
|
Hengyang King Xing Lifeng New Materials Co., Ltd. |
|
CHINA |
|
Tantalum |
|
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Tantalum |
|
LSM Brasil S.A. |
|
BRAZIL |
|
Tantalum |
|
Mineracao Taboca S.A. |
|
BRAZIL |
|
Tantalum |
|
NPM Silmet AS |
|
ESTONIA |
|
Tantalum |
|
Telex Metals |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
KEMET Blue Metals |
|
MEXICO |
|
Tantalum |
|
KEMET Blue Powder |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
Metallurgical Products India Pvt., Ltd. |
|
INDIA |
|
Tantalum |
|
QuantumClean |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
Yanling Jincheng Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Tantalum |
|
Asaka Riken Co., Ltd. |
|
JAPAN |
|
Tantalum |
|
D Block Metals, LLC |
|
UNITED STATES OF AMERICA |
|
Tantalum |
|
FIR Metals & Resource Ltd. |
|
CHINA |
|
Tantalum |
|
H.C. Starck Smelting GmbH & Co. KG |
|
GERMANY |
|
Tantalum |
|
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Tantalum |
|
Jiangxi Tuohong New Raw Material |
|
CHINA |
|
Tantalum |
|
Jiujiang Janny New Material Co., Ltd. |
|
CHINA |
|
Tantalum |
|
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
|
CHINA |
|
Tantalum |
|
Power Resources Ltd. |
|
NORTH MACEDONIA, REPUBLIC OF |
|
Tantalum |
|
Resind Industria e Comercio Ltda. |
|
BRAZIL |
|
Tantalum |
|
XinXing HaoRong Electronic Material Co., Ltd. |
|
CHINA |
|
Tin |
|
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
|
CHINA |
|
|
|
|
|
|
|
Tin |
|
Alpha |
|
UNITED STATES OF AMERICA |
|
Tin |
|
CV Gita Pesona |
|
INDONESIA |
|
Tin |
|
PT Aries Kencana Sejahtera |
|
INDONESIA |
|
Tin |
|
PT Premium Tin Indonesia |
|
INDONESIA |
|
Tin |
|
CV United Smelting |
|
INDONESIA |
|
Tin |
|
Dowa |
|
JAPAN |
|
Tin |
|
EM Vinto |
|
BOLIVIA (PLURINATIONAL STATE OF) |
|
Tin |
|
Fenix Metals |
|
POLAND |
|
Tin |
|
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
|
CHINA |
|
Tin |
|
Huichang Jinshunda Tin Co., Ltd. |
|
CHINA |
|
Tin |
|
Gejiu Kai Meng Industry and Trade LLC |
|
CHINA |
|
Tin |
|
China Tin Group Co., Ltd. |
|
CHINA |
|
Tin |
|
Malaysia Smelting Corporation (MSC) |
|
MALAYSIA |
|
Tin |
|
Metallic Resources, Inc. |
|
UNITED STATES OF AMERICA |
|
Tin |
|
Mineracao Taboca S.A. |
|
BRAZIL |
|
Tin |
|
Minsur |
|
PERU |
|
Tin |
|
Mitsubishi Materials Corporation |
|
JAPAN |
|
Tin |
|
Jiangxi New Nanshan Technology Ltd. |
|
CHINA |
|
Tin |
|
O.M. Manufacturing (Thailand) Co., Ltd. |
|
THAILAND |
|
Tin |
|
Operaciones Metalurgicas S.A. |
|
BOLIVIA (PLURINATIONAL STATE OF) |
|
Tin |
|
PT Artha Cipta Langgeng |
|
INDONESIA |
|
Tin |
|
PT Babel Inti Perkasa |
|
INDONESIA |
|
Tin |
|
PT Bangka Tin Industry |
|
INDONESIA |
|
Tin |
|
PT Belitung Industri Sejahtera |
|
INDONESIA |
|
Tin |
|
PT Bukit Timah |
|
INDONESIA |
|
Tin |
|
PT DS Jaya Abadi |
|
INDONESIA |
|
Tin |
|
PT Mitra Stania Prima |
|
INDONESIA |
|
Tin |
|
PT Panca Mega Persada |
|
INDONESIA |
|
Tin |
|
PT Prima Timah Utama |
|
INDONESIA |
|
Tin |
|
PT Refined Bangka Tin |
|
INDONESIA |
|
Tin |
|
PT Sariwiguna Binasentosa |
|
INDONESIA |
|
Tin |
|
PT Stanindo Inti Perkasa |
|
INDONESIA |
|
Tin |
|
PT Sumber Jaya Indah |
|
INDONESIA |
|
Tin |
|
PT Timah Tbk Kundur |
|
INDONESIA |
|
Tin |
|
PT Timah Tbk Mentok |
|
INDONESIA |
|
Tin |
|
PT Tinindo Inter Nusa |
|
INDONESIA |
|
Tin |
|
PT Tommy Utama |
|
INDONESIA |
|
Tin |
|
Rui Da Hung |
|
TAIWAN, PROVINCE OF CHINA |
|
Tin |
|
Soft Metais Ltda. |
|
BRAZIL |
|
Tin |
|
Thaisarco |
|
THAILAND |
|
Tin |
|
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
|
CHINA |
|
Tin |
|
White Solder Metalurgia e Mineracao Ltda. |
|
BRAZIL |
|
Tin |
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
|
CHINA |
|
Tin |
|
Yunnan Tin Company Limited |
|
CHINA |
|
Tin |
|
CV Venus Inti Perkasa |
|
INDONESIA |
|
Tin |
|
Magnu’s Minerais Metais e Ligas Ltda. |
|
BRAZIL |
|
Tin |
|
Melt Metais e Ligas S.A. |
|
BRAZIL |
|
Tin |
|
PT ATD Makmur Mandiri Jaya |
|
INDONESIA |
|
Tin |
|
O.M. Manufacturing Philippines, Inc. |
|
PHILIPPINES |
|
Tin |
|
PT Inti Stania Prima |
|
INDONESIA |
|
Tin |
|
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
|
VIET NAM |
|
Tin |
|
Nghe Tinh Non-Ferrous Metals Joint Stock Company |
|
VIET NAM |
|
|
|
|
|
|
|
Tin |
|
Tuyen Quang Non-Ferrous Metals Joint Stock Company |
|
VIET NAM |
|
Tin |
|
CV Dua Sekawan |
|
INDONESIA |
|
Tin |
|
PT Rajehan Ariq |
|
INDONESIA |
|
Tin |
|
An Vinh Joint Stock Mineral Processing Company |
|
VIET NAM |
|
Tin |
|
Resind Industria e Comercio Ltda. |
|
BRAZIL |
|
Tin |
|
Metallo Belgium N.V. |
|
BELGIUM |
|
Tin |
|
Metallo Spain S.L.U. |
|
SPAIN |
|
Tin |
|
PT Bangka Prima Tin |
|
INDONESIA |
|
Tin |
|
PT Sukses Inti Makmur |
|
INDONESIA |
|
Tin |
|
PT Kijang Jaya Mandiri |
|
INDONESIA |
|
Tin |
|
PT Menara Cipta Mulia |
|
INDONESIA |
|
Tin |
|
HuiChang Hill Tin Industry Co., Ltd. |
|
CHINA |
|
Tin |
|
Gejiu Fengming Metallurgy Chemical Plant |
|
CHINA |
|
Tin |
|
Guanyang Guida Nonferrous Metal Smelting Plant |
|
CHINA |
|
Tin |
|
Modeltech Sdn Bhd |
|
MALAYSIA |
|
Tin |
|
Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
|
CHINA |
|
Tin |
|
Chifeng Dajingzi Tin Industry Co., Ltd. |
|
CHINA |
|
Tin |
|
Estanho de Rondonia S.A. |
|
BRAZIL |
|
Tin |
|
Gejiu Zili Mining And Metallurgy Co., Ltd. |
|
CHINA |
|
Tin |
|
Pongpipat Company Limited |
|
MYANMAR |
|
Tin |
|
PT Babel Surya Alam Lestari |
|
INDONESIA |
|
Tin |
|
PT Bangka Serumpun |
|
INDONESIA |
|
Tin |
|
PT Tirus Putra Mandiri |
|
INDONESIA |
|
Tin |
|
Super Ligas |
|
BRAZIL |
|
Tin |
|
Tin Technology & Refining |
|
UNITED STATES OF AMERICA |
|
Tungsten |
|
A.L.M.T. Corp. |
|
JAPAN |
|
Tungsten |
|
Kennametal Huntsville |
|
UNITED STATES OF AMERICA |
|
Tungsten |
|
Chenzhou Diamond Tungsten Products Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Chongyi Zhangyuan Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Ganzhou Huaxing Tungsten Products Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Ganzhou Seadragon W & Mo Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Global Tungsten & Powders Corp. |
|
UNITED STATES OF AMERICA |
|
Tungsten |
|
Guangdong Xianglu Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
H.C. Starck Tungsten GmbH |
|
GERMANY |
|
Tungsten |
|
Hunan Chunchang Nonferrous Metals Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Japan New Metals Co., Ltd. |
|
JAPAN |
|
Tungsten |
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Tejing (Vietnam) Tungsten Co., Ltd. |
|
VIET NAM |
|
Tungsten |
|
Wolfram Bergbau und Hutten AG |
|
AUSTRIA |
|
Tungsten |
|
Xiamen Tungsten (H.C.) Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Xiamen Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Hunan Chenzhou Mining Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Kennametal Fallon |
|
UNITED STATES OF AMERICA |
|
Tungsten |
|
Masan Tungsten Chemical LLC (MTC) |
|
VIET NAM |
|
Tungsten |
|
Fujian Jinxin Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Hydrometallurg, JSC |
|
RUSSIAN FEDERATION |
|
Tungsten |
|
Jiangxi Gan Bei Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
ACL Metais Eireli |
|
BRAZIL |
|
Tungsten |
|
Asia Tungsten Products Vietnam Ltd. |
|
VIET NAM |
|
Tungsten |
|
Ganzhou Haichuang Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
H.C. Starck Smelting GmbH & Co. KG |
|
GERMANY |
|
Tungsten |
|
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
|
CHINA |
|
Tungsten |
|
Hunan Litian Tungsten Industry Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Jiangxi Dayu Longxintai Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Jiangxi Yaosheng Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Malipo Haiyu Tungsten Co., Ltd. |
|
CHINA |
|
Tungsten |
|
Moliren Ltd. |
|
RUSSIAN FEDERATION |
|
Tungsten |
|
Niagara Refining LLC |
|
UNITED STATES OF AMERICA |
|
Tungsten |
|
Philippine Chuangxin Industrial Co., Inc. |
|
PHILIPPINES |
|
Tungsten |
|
South-East Nonferrous Metal Company Limited of Hengyang City |
|
CHINA |
|
Tungsten |
|
Unecha Refractory metals plant |
|
RUSSIAN FEDERATION |
|
Tungsten |
|
Woltech Korea Co., Ltd. |
|
KOREA, REPUBLIC OF |
|
Tungsten |
|
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. |
|
CHINA |
(1)These smelters are located in Covered Countries, list Covered Countries as sources of Conflict Minerals, and are not certified as conformant by the RMAP. They were both listed by a single Identified Supplier that is also subject to the Dodd Frank Act and has adopted its own Conflict Minerals Policy in which it commits to take the required steps over time to source from socially responsible suppliers when the choice of supplier is within its control. As Control4 does not have a direct relationship with these smelters or refiners, we will continue to encourage the Identified Supplier to further refine their due diligence and to responsibly source any Conflict Minerals used in Control4’s Covered Products.
Schedule 2
Countries of Origin
|
Angola(1) |
|
Guyana |
|
Philippines |
|
Argentina |
|
Hong Kong |
|
Poland |
|
Armenia |
|
Hungary |
|
Portugal |
|
Australia |
|
India |
|
Republic of Korea |
|
Austria |
|
Indonesia |
|
Russian Federation |
|
Belarus |
|
Ireland |
|
Rwanda(1) |
|
Belgium |
|
Israel |
|
Saudi Arabia |
|
Bermuda |
|
Italy |
|
Sierra Leone |
|
Bolivia |
|
Ivory Coast |
|
Singapore |
|
Brazil |
|
Japan |
|
Slovakia |
|
Burundi(1) |
|
Jersey |
|
South Africa |
|
Cambodia |
|
Kazakhstan |
|
South Sudan(1) |
|
Canada |
|
Kenya |
|
Spain |
|
Central African Republic(1) |
|
Kyrgyzstan |
|
Suriname |
|
Chile |
|
Laos |
|
Sweden |
|
China |
|
Luxembourg |
|
Switzerland |
|
Colombia |
|
Madagascar |
|
Taiwan |
|
The Republic of the Congo(1) |
|
Malaysia |
|
Tajikistan |
|
Czech Republic |
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Mali |
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Tanzania(1) |
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Djibouti |
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Mexico |
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Thailand |
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Democratic Republic of the Congo(1) |
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Mongolia |
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Turkey |
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Ecuador |
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Morocco |
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Uganda(1) |
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Egypt |
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Mozambique |
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United Arab Emirates |
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Estonia |
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Myanmar |
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United Kingdom |
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Ethiopia |
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Namibia |
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United States |
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EU |
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Netherlands |
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Uzbekistan |
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Finland |
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New Zealand |
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Viet Nam |
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France |
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Niger |
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Zambia(1) |
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Germany |
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Nigeria |
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Zimbabwe |
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Ghana |
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Papua New Guinea |
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|
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Guinea |
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Peru |
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(1)The smelters and refiners sourcing Conflict Minerals originating from these Covered Countries have not been audited by the RMAP. However, all the smelters and refiners sourcing Conflict Minerals from the Covered Countries stem from one of Control4’s Identified Suppliers. We note that this Identified Supplier is also subject to the Dodd Frank Act and has adopted its own Conflict Minerals Policy in which it commits to take the required steps over time to source from socially responsible suppliers when the choice of supplier is within its control. As Control4 does not have a direct relationship with these smelters or refiners, we will continue to encourage the Identified Supplier to further refine their due diligence and to responsibly source any Conflict Minerals used in Control4’s Covered Products.