Exhibit 1.01
CONFLICT MINERALS REPORT
INTEL CORPORATION
IN ACCORD WITH RULE 13P-1 UNDER THE SECURITIES EXCHANGE ACT OF 1934
This Conflict Minerals Report (Report) of Intel Corporation (Intel or we) for the year ended December 31, 2019 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting requirements related to conflict minerals, defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are currently limited to tantalum, tin, and tungsten.
The Rule imposes certain reporting obligations on SEC registrants whose products contain conflict minerals that are necessary to the functionality or production of their products (referred to as necessary conflict minerals). For products that contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the necessary conflict minerals originated in the Democratic Republic of the Congo (DRC) or an adjoining country (collectively, the Covered Countries). If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals originated or may have originated in a Covered Country and may not be solely from recycled or scrap sources, the registrant must conduct due diligence to determine if the necessary conflict minerals directly or indirectly financed or benefited armed groups (as defined by the SEC in Form SD) in the Covered Countries.
Overview of Intels Responsible Minerals Program and Commitment to Responsible Sourcing
As set forth in our Responsible Minerals Sourcing Policy, Intel is committed to the responsible sourcing of minerals, which we define as sourcing done in an ethical and sustainable manner that safeguards the human rights of everyone in our global supply chain. Intels responsible minerals program continues to expand in scope to include additional minerals, such as cobalt, and to examine human rights risks in Conflict-Affected and High-Risk Areas (CAHRAs) globally, as defined by 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, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, OECD Guidance). While the focus of this Report is on conflict minerals and the Covered Countries, we are electing to also describe the proactive due diligence we began several years ago around cobalt. Cobalt is used in our next-generation microprocessor manufacturing technology; in following through with our commitment to pursuing responsible minerals sourcing, we have included a separate section discussing our programs efforts to address cobalt.
As we expand our program, we also continue to strengthen our approach for responsible sourcing of conflict minerals and to support the improvement of conditions of the mining communities in the Covered Countries. Many of our hardware products contain tantalum, tin, tungsten, and/or gold necessary to the functionality or production of those products. Conflict minerals are obtained from sources worldwide, and our desire is not to eliminate those originating in the Covered Countries and other CAHRAs, but rather to obtain conflict minerals from sources that do not directly or indirectly finance or benefit armed groups or contribute to human rights abuses. We believe that it is important for us and other companies to support responsible in-region mineral sourcing from the Covered Countries and other CAHRAs, in order to not negatively affect the economies of such countries.
We have worked extensively for over a dozen years on the issue of conflict minerals, as part of our work on responsible mineral sourcing. We recognize that broad collaborative efforts among governments, non-governmental organizations, civil society experts, and industry are needed to identify and mitigate the risk of contributing to serious human rights abuses and conflict related to mineral extraction in the Covered Countries. Intel is a steering committee member of the Responsible Minerals Initiative (RMI), unique member code INTC, and active contributor to multiple RMI sub-teams.
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Intel is also an active member of the OECD Multi-Stakeholder Steering Group, which advises on implementation for the OECD Guidance, and the European Partnership for Responsible Minerals, where we collaborate with companies in the electronics and other industries (e.g., jewelry, automotive, medical instrumentation, and others) and other stakeholders, such as public authorities and civil society groups, to address responsible mineral sourcing issues. Additionally, we are members of, and provide support to, the International Tin Associations International Tin Supply Chain Initiative (iTSCi) and the Public-Private Alliance for Responsible Minerals Trade (PPA), which promote responsibly sourced minerals from the Covered Countries. We are also part of the CRAFT Code Committee, which assisted in the development of the Code of Risk-mitigation for Artisanal and Small-Scale Mining engaging in Formal Trade (CRAFT).
Additionally, in 2019, Intel participated in a PPA-organized delegation visit to the DRC and Rwanda to provide a customer voice and collaborate with key partners and stakeholders in strengthening due diligence and credible traceability measures. This delegation included meetings with government leaders and human rights advocates as well as visits to several mine sites and direct interaction with miners. Intel believes that maintaining a connection to upstream actors, local communities, and regulating bodies is important in refining industry-wide processes and standards as well as in setting strategies that aim to improve conditions in the region.
Products and Supply Chain Description
The Intel products we manufactured or contracted with others to manufacture that may contain necessary conflict minerals, and which are covered in this Report, are our microprocessor and chipset products, including Celeron®, Pentium®, Intel® Core, Intel® Xeon®, Intel® Quark, and Intel Atom® processors; Intel® Agilex, Intel® Stratix®, Intel® Arria®, Intel® Cyclone®, and Intel® MAX® FPGAs; Intel® eASIC ASICs; Intel® Enpirion® Power Solutions and Mobileye EyeQ® family of system-on-chip (SoC) devices; and our other server products, networking products, boards and kits, memory and storage products, and our other Mobileye products.
Most of our hardware products, primarily microprocessors, chipsets and their packages, are manufactured in our own network of fabrication facilities (fabs). Intel also sells products that are manufactured for us by other companies and products that include ready-made component parts that we purchase from third parties. Although many of our hardware products contain conflict minerals, we do not purchase ore or unrefined conflict minerals from mines. We are many steps removed in the supply chain from the mining of minerals and are therefore considered a downstream purchaser. We purchase materials used in our products from a large network of suppliers; some of those materials contribute necessary conflict minerals to our products. The origin of minerals cannot be determined with any certainty once the ores are smelted, refined and converted to ingots, bullion or other derivatives. The smelters and refiners (referred to as facilities) are consolidating points for ore and are in the best position in the total supply chain to know the origin of the ores. We rely on our suppliers to assist with our reasonable country of origin inquiry and due diligence efforts, including the identification of smelters and refiners, for the minerals contained in the materials which they supply to us.
Design of Responsible Minerals Program
The design of Intels responsible minerals program is in conformity with the OECD Guidance specifically as it relates to our position in the minerals supply chain as a downstream purchaser. Summarized below are the design components of our responsible minerals program as they relate to the five-step framework from the OECD Guidance. While our program encompasses a broader scope of minerals and regional areas, the summary of Steps 2 through 5 below focuses on the application of our program to conflict minerals and the Covered Countries.
1. | Maintain strong company management systems: |
| Responsible Minerals Sourcing Policy: Maintain a supply chain policy for minerals originating from CAHRAs, including conflict minerals originating from the Covered Countries. This policy outlines our commitment to responsible mineral sourcing from CAHRAs, our commitment to exercise due diligence consistent with the OECD Guidance, and expectations that our suppliers have similarly established due diligence programs. Our policy is publicly available and can be found at www.intel.com/conflictfree. |
| Internal Responsible Minerals team: Operate an internal responsible minerals team led by our Global Supply Chain organization to implement our Responsible Minerals Sourcing Policy. We review such efforts with our Chief Executive Officer (CEO) and senior management of our Technology, Systems Architecture, and Client Group (TSCG). |
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| Supply chain control system: Employ a supply chain system of controls and transparency through the use of due diligence tools such as the Conflict Minerals Reporting Template (CMRT), a supply chain survey designed by the RMI to identify the smelters and refiners that process the necessary conflict minerals contained in our products and the country of origin of those conflict minerals. We employ a database to assess due diligence information and maintain records relating to our responsible minerals program for at least five years, in accordance with our record retention guidelines. |
| Supplier engagement: Feature requirements related to responsible mineral sourcing in our standard template for supplier contracts and specifications so that current and future suppliers are obligated to comply with our policies on responsible minerals sourcing, including participation in a supply chain survey and related due diligence activities. We communicate our Responsible Minerals Sourcing Policy and contractual requirements to relevant suppliers annually. |
| Company grievance mechanism: Enable employees, suppliers and other stakeholders to report any concerns relating to our responsible minerals program through our online corporate responsibility reporting and grievance mechanism found on our company website at https://www.intel.com/content/www/us/en/corporate-responsibility/corporate-responsibility.html. |
2. | Identify and assess risks in our supply chain: |
| Identify smelters/refiners in our supply chain: Identify direct suppliers that supply products to Intel that may contribute necessary conflict minerals to our products. Conduct an annual supply chain survey requesting those direct suppliers to provide a conflict minerals declaration, using the CMRT, designed to identify the conflict minerals contained in the products they supply to Intel, the smelters and refiners that processed those conflict minerals, and the country of origin of those conflict minerals. We evaluate the completeness and accuracy of the suppliers survey responses and contact suppliers whose survey response we identified as having contained incomplete or potentially inaccurate information in order to seek additional clarifying information. |
| Identify the scope of the risk assessment: Our risk assessment is designed to identify risks in our supply chain. This includes direct suppliers not meeting our contractual requirements related to conflict minerals as well as smelters and refiners that are not conformant to a responsible mineral sourcing validation program or that we have reason to believe may source conflict minerals from the Covered Countries. We document mineral country of origin information for the smelters and refiners identified by the supply chain survey, as provided from sources including the supply chain survey, responsible mineral sourcing validation programs, direct contact with smelters and refiners, and from publicly available sources such as smelter and refiner websites. |
| Assess due diligence practices of smelters and refiners: Compare smelters and refiners identified by the supply chain survey against the list of facilities that are conformant to a responsible mineral sourcing validation program such as the RMIs Responsible Minerals Assurance Program (RMAP), and other RMI cross-recognized, independent third party audit programs. |
| Carry out spot checks of smelters and refiners: Conduct spot checks of smelter and refiner due diligence practices by attempting to visit those facilities that are not conformant to a responsible mineral sourcing validation program and which allowed our visit. Our smelter and refiner visits are designed to assess their due diligence practices, request country of origin and chain of custody information for the conflict minerals processed by the facilities and encourage and assist their participation in such a program. |
3. | Execute a strategy to respond to identified risks: |
| Report findings to senior management: Provide progress reports to our CEO and TSCG senior management summarizing information gathered during our annual supply chain survey, results from the risk assessment process and status of our risk mitigation efforts. |
| Devise and adopt a risk management plan: Maintain a risk management plan that includes due diligence reviews of suppliers, smelters and refiners that may be sourcing or processing conflict minerals from Covered Countries and other CAHRAs which may not be from recycled or scrap sources. Our due diligence measures are significantly based on responsible mineral sourcing validation programs that evaluate the procurement practices of the smelters and refiners that process and provide those conflict minerals to our supply chain. |
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| Implement a risk management plan: Perform risk mitigation efforts to bring suppliers into conformity with our Responsible Minerals Sourcing Policy or contractual requirements, which efforts may include working with direct suppliers to consider an alternative source for the necessary conflict minerals. We attempt to contact smelter and refiner facilities that are not conformant to a responsible mineral sourcing validation program to assess their due diligence practices, request country of origin and chain of custody information for the conflict minerals processed by the facilities and encourage and assist their participation in such a program. |
| Ongoing risk monitoring: Monitor and track suppliers, smelters, and refiners identified as not meeting the requirements set forth in our Responsible Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements. |
4. | Support the development and implementation of independent third party audits of smelters and refiners sourcing: |
| Support development and implementation of due diligence practices and tools such as the CMRT through our leadership in the RMIs Steering Committee and participation within RMI sub-teams. |
| Support development and implementation of the RMAP by defining the terms of the RMAP audit protocol in conjunction with RMI member companies and other industry groups. |
| Support responsible mineral sourcing validation programs that carry out independent third party audits of smelter and refiner facilities, such as the RMAP, through our membership in and financial support of the RMI, including a 2019 donation to the Upstream Due Diligence Fund to financially support smelters and refiners to conduct due diligence on their sourcing from CAHRAs. |
5. | Report on supply chain due diligence: |
| Publicly communicate our Responsible Minerals Sourcing Policy on our company website at www.intel.com/conflictfree. |
| Report annually on our supply chain due diligence activities in our white paper titled Intels Efforts to Achieve a Responsibly Sourced Mineral Supply Chain and Corporate Responsibility Report available on our company website at www.intel.com/conflictfree. |
| Obtain an independent private sector audit of applicable sections of this Report and file a Form SD with the SEC. This information is publicly available on our company website at www.intel.com/conflictfree. |
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.
Description of Reasonable Country of Origin Inquiry Efforts
For 2019, our reasonable country of origin inquiry (RCOI) efforts for conflict minerals included conducting a supply chain survey of our direct suppliers (referred to as surveyed suppliers) using the CMRT. The supply chain surveys requested our suppliers to identify the smelters and refiners and countries of origin of the conflict minerals in products they supply to us. We compared the smelters and refiners identified in the surveys against the lists of facilities which are conformant to a responsible mineral sourcing validation program, such as the RMAP or RMI cross-recognized programs. We also proactively attempted to contact smelter and refiner facilities identified by our surveyed suppliers where we did not have mineral country of origin information and requested each facility contacted to identify the types of raw materials processed by the facility and the mineral country of origin for ore processed by that facility. We documented country of origin information for the smelter and refiner facilities identified by surveyed suppliers as provided from sources including the supply chain survey, responsible mineral sourcing validation programs, direct contact with smelters and refiners, and from publicly available sources such as smelter and refiner websites, if we determined such publicly available sources to be reliable.
Results of Reasonable Country of Origin Inquiry Efforts
For 2019, Intel conducted a supply chain survey of 200 suppliers that we determined may contribute necessary conflict minerals to our products.
The results of our RCOI as of March 3, 2020 are as follows:
| 96% of surveyed suppliers provided a CMRT in response to our supply chain survey request. |
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| The surveyed suppliers identified 227 operational smelter and refiner facilities which may process the necessary conflict minerals contained in the products provided to us. |
| We know or have reason to believe that a portion of the conflict minerals processed by 43 of these 227 smelters and refiners may have originated in the Covered Countries and may not be solely from recycled or scrap sources. |
Of the 200 surveyed suppliers, 51 were suppliers specific to Mobileye, an Intel subsidiary, that were not otherwise part of the Intel supply chain (Mobileye-unique suppliers). As of March 3, 2020, 43 of the 51 Mobileye-unique suppliers, approximately 84%, had provided a CMRT in response to our supply chain survey request. Our response rate for Mobileye-unique suppliers is not meeting the overall goal that Intel expects from its supply chain (excluding Mobileye-unique suppliers, our supplier response rate was 100%). Intels supplier due diligence with these remaining suppliers is ongoing and we are continuing work on our escalation paths to increase the response rate.
Conclusion Based on Reasonable Country of Origin Inquiry
We have concluded in good faith that during 2019:
a) | Intel manufactured and contracted with others to manufacture products as to which conflict minerals are necessary to the functionality or production of our products. |
b) | Based on our RCOI, we know or have reason to believe that a portion of the necessary conflict minerals contained in our products originated or may have originated in the Covered Countries and know or have reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources. |
As a result of the above conclusion and pursuant to the Rule, we undertook due diligence measures on the source and chain of custody of the necessary conflict minerals in our products which we had reason to believe may have originated from the Covered Countries and which may not have come from recycled or scrap sources. There is significant overlap between our RCOI efforts and our due diligence measures performed.
Description of Due Diligence Measures Performed
Below is a description of the measures performed for this reporting period, as of March 3, 2020, to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products:
| Conducted a supply chain survey of suppliers which we identified may be supplying Intel with products that contain necessary conflict minerals using the CMRT, requesting country of origin information regarding the necessary conflict minerals and identification of smelters and refiners that process such minerals. |
| Contacted surveyed suppliers on responses to supply chain surveys that we identified as having contained incomplete or potentially inaccurate information to seek additional clarifying information. |
| Received a CMRT from 96% of our surveyed suppliers in response to our supply chain survey request. |
| Compared smelters and refiners identified by surveyed suppliers against the list of facilities that are conformant to a responsible mineral sourcing validation program. |
| Monitored and tracked surveyed suppliers, and smelters and refiners identified by surveyed suppliers, which we identified as not meeting our Responsible Minerals Sourcing Policy or contractual requirements, to determine their progress in meeting those requirements. |
| Performed risk mitigation efforts with surveyed suppliers we identified as not in conformity with our Responsible Minerals Sourcing Policy or contractual requirements by working with them to bring them into compliance. |
| In 2019, visited three smelters and refiners that were not conformant to a responsible mineral sourcing validation program to encourage and assist their participation in such a program. |
| Provided 13 progress reports to TSCG senior management and two progress reports to our CEO that summarized the status of our responsible minerals program. |
| Obtained an independent private sector audit of applicable sections of this Report, which is set forth as Exhibit A to this Report. |
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Results of our Due Diligence Measures
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of products which contain conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by responsible mineral sourcing validation programs. Such sources of information, as well as our smelters and refiner facility visits and publicly available sources, may yield inaccurate or incomplete information and may be subject to fraud.
Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold, and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers and the entire supply chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold, and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners. We ask that the data cover the entire reporting year, and we seek to use contract provisions requiring the suppliers to promptly update us in the event the sourcing data changes. Our due diligence processes are ongoing throughout the year.
Surveyed Supplier Due Diligence Results
Intel evaluated the accuracy and completeness of the responses to our supply chain surveys by our surveyed suppliers. We identified 22 surveyed suppliers whose initial survey response contained incomplete or potentially inaccurate information. We used various methods to identify the incomplete or inaccurate information in the surveyed suppliers response, including verification checks conducted by third party software or by members of our internal Responsible Minerals team. When an incomplete or inaccurate response was identified, we contacted the applicable surveyed supplier, identified the incomplete or inaccurate information, and requested that the surveyed supplier correct the incomplete or potentially inaccurate information and provide an updated response. 19 of these 22 surveyed suppliers provided an updated CMRT which we determined, using the same evaluation criteria, to be complete and accurate. We continue to work with the remaining suppliers on capacity building to ensure accuracy of future declarations.
Upon receiving a survey response identified to be complete and accurate based on our evaluation criteria, we further evaluated each response for conformity with our Responsible Minerals Sourcing Policy or contractual requirements. These requirements include that our surveyed suppliers must maintain a publicly available conflict minerals sourcing policy, provide a CMRT upon our request, and use smelters and refiners which are either conformant to a responsible mineral sourcing validation program or have begun participating in such a program. We identified surveyed suppliers which were not fully compliant with all applicable requirements and monitored and tracked these suppliers progress in meeting the applicable requirements. We performed risk mitigation efforts by contacting each supplier, identifying actions items which we requested the supplier complete, and asking the supplier to provide an updated CMRT. Our risk mitigation efforts are specifically related to meeting our Responsible Minerals Sourcing Policy or contractual requirements, with the goal of bringing each surveyed supplier into compliance with such requirements.
As a result of these supplier due diligence activities, Intel determined that approximately 95% of the surveyed suppliers that had provided a CMRT as of March 3, 2020 (183 out of 192) are in compliance with our Responsible Minerals Sourcing Policy or contractual requirements. Of the nine suppliers not meeting our requirements, two met requirements subsequent to March 3, and we are continuing to work with the other seven suppliers to drive compliance.
Smelter and Refiner Due Diligence Results
As a result of the supply chain survey, our surveyed suppliers identified an aggregate of 227 operational smelter and refiner facilities which may process the necessary conflict minerals contained in the products these surveyed suppliers provided to Intel.
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Intel conducted due diligence on these smelters and refiners. Our due diligence activities are dominated by a continual process to determine and monitor whether the identified smelters and refiners are operational and therefore may contribute necessary conflict minerals to our final products, and whether they are conformant to a responsible mineral sourcing validation program or have begun participating in such a program. We sought reliable information on the source and chain of custody of the conflict minerals processed by such facilities, including from publicly available sources, with the goal to determine if any of these facilities processed conflict minerals that may have originated from the Covered Countries and other CAHRAs, and may not be solely from recycled or scrap sources. We also visited two conformant smelters and refiners in our supply chain to better understand their due diligence and procurement practices.
If a smelter or refiner in our supply chain was not yet conformant to a responsible mineral sourcing validation program or had not yet begun participating in such a program, Intel and other RMI member companies proactively attempted to contact such facilities to request country of origin information for the conflict minerals the facilities processed, as well as to encourage and assist their participation in a responsible mineral sourcing validation program and, in some cases, visited such facilities on-site. We monitored and tracked smelters and refiners which we identified as not being conformant to a responsible mineral sourcing validation program or not having begun participating in such a program.
During this reporting year, we identified 23 smelter and refiner facilities that were not conformant to a responsible mineral sourcing validation program. These facilities were the focus of our smelter and refiner due diligence activities for this reporting period and, as a result of our activities, we reasonably concluded that as of March 3, 2020:
| 20 of these 23 smelter and refiner facilities had later become conformant to a responsible mineral sourcing program. |
| Two of these 23 smelter and refiner facilities have begun participating in a responsible mineral sourcing validation program but are not yet conformant. Based on Intels due diligence, we have no reason to believe these facilities sourced conflict minerals from the Covered Countries. |
| The remaining facility decided not to continue participating in a responsible mineral sourcing program. Intel is now in the process of removing this refiner from the supply chain and, subsequent to March 3, successfully achieved removal of this refiner from all but one supplier. Based on Intels due diligence, we have no reason to believe this refiner sourced conflict minerals from the Covered Countries. |
As result of our due diligence activities summarized above, we determined the following as of March 3, 2020:
| All 227 smelters and refiners identified by our surveyed suppliers are either conformant to a responsible mineral sourcing validation program, have begun participating in such a program, or with respect to the one remaining facility, is a facility that, based on our own due diligence activities, we have no reason to believe processed conflict minerals which originated from the Covered Countries. |
| All 43 smelters and refiners which we know or have reason to believe may source conflict minerals from the Covered Countries which may not be solely from recycled or scrap sources are conformant to a responsible mineral sourcing validation program. |
| We have no reason to believe that any of the 227 smelter and refiner facilities directly or indirectly finance or benefit armed groups in the Covered Countries. |
Below is a summary of the mineral country of origin information collected as of March 3, 2020 as a result of our due diligence activities:
Table 1
Country of Origin |
Metal | |
Argentina |
Gold | |
Australia |
Gold | |
Azerbaijan |
Gold | |
Benin |
Gold | |
Bolivia |
Gold | |
Botswana |
Gold | |
Brazil |
Gold | |
Burkina Faso |
Gold |
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Country of Origin |
Metal | |
Canada |
Gold | |
Chile |
Gold | |
China |
Gold | |
Colombia |
Gold | |
Congo, Democratic Republic of the** |
Gold | |
Cuba* |
Gold | |
Cyprus |
Gold | |
Dominican Republic |
Gold | |
Ecuador |
Gold | |
Egypt |
Gold | |
Eritrea |
Gold | |
Ethiopia |
Gold | |
Fiji |
Gold | |
Finland |
Gold | |
Georgia |
Gold | |
Ghana |
Gold | |
Guatemala |
Gold | |
Guinea |
Gold | |
Guyana |
Gold | |
Honduras |
Gold | |
Indonesia |
Gold | |
Iran* |
Gold | |
Ivory Coast |
Gold | |
Japan |
Gold | |
Kazakhstan |
Gold | |
Kenya |
Gold | |
Laos |
Gold | |
Liberia |
Gold | |
Malaysia |
Gold | |
Mali |
Gold | |
Mauritania |
Gold | |
Mexico |
Gold | |
Mongolia |
Gold | |
Morocco |
Gold | |
Namibia |
Gold | |
Netherlands |
Gold | |
New Zealand |
Gold | |
Nicaragua |
Gold | |
Niger |
Gold | |
Papua New Guinea |
Gold | |
Peru |
Gold | |
Philippines |
Gold | |
Puerto Rico |
Gold | |
Russian Federation |
Gold | |
Rwanda** |
Gold | |
Saudi Arabia |
Gold | |
Senegal |
Gold | |
Serbia |
Gold | |
Slovakia |
Gold | |
Solomon Islands |
Gold | |
South Africa |
Gold | |
Spain |
Gold | |
Suriname |
Gold | |
Swaziland |
Gold | |
Sweden |
Gold |
8
Country of Origin |
Metal | |
Tajikistan |
Gold | |
Tanzania** |
Gold | |
Togo |
Gold | |
Turkey |
Gold | |
Uganda** |
Gold | |
United Kingdom |
Gold | |
United States of America |
Gold | |
Uruguay |
Gold | |
Zambia** |
Gold | |
Zimbabwe |
Gold | |
Australia |
Tantalum | |
Austria |
Tantalum | |
Bolivia |
Tantalum | |
Brazil |
Tantalum | |
Burundi** |
Tantalum | |
China |
Tantalum | |
Colombia |
Tantalum | |
Congo, Democratic Republic of the** |
Tantalum | |
Ethiopia |
Tantalum | |
France |
Tantalum | |
Germany |
Tantalum | |
Guinea |
Tantalum | |
India |
Tantalum | |
Madagascar |
Tantalum | |
Malaysia |
Tantalum | |
Mozambique |
Tantalum | |
Namibia |
Tantalum | |
Nigeria |
Tantalum | |
Russian Federation |
Tantalum | |
Rwanda** |
Tantalum | |
Sierra Leone |
Tantalum | |
Somaliland |
Tantalum | |
Spain |
Tantalum | |
Thailand |
Tantalum | |
Zimbabwe |
Tantalum | |
Australia |
Tin | |
Bolivia |
Tin | |
Brazil |
Tin | |
Burundi** |
Tin | |
China |
Tin | |
Colombia |
Tin | |
Congo, Democratic Republic of the** |
Tin | |
Guinea |
Tin | |
Indonesia |
Tin | |
Laos |
Tin |
9
Country of Origin |
Metal | |
Malaysia |
Tin | |
Mongolia |
Tin | |
Myanmar |
Tin | |
Nigeria |
Tin | |
Peru |
Tin | |
Portugal |
Tin | |
Russian Federation |
Tin | |
Rwanda** |
Tin | |
Taiwan |
Tin | |
Thailand |
Tin | |
Uganda** |
Tin | |
United Kingdom |
Tin | |
Venezuela* |
Tin | |
Vietnam |
Tin | |
Australia |
Tungsten | |
Bolivia |
Tungsten | |
Brazil |
Tungsten | |
Burundi** |
Tungsten | |
China |
Tungsten | |
Colombia |
Tungsten | |
Congo, Democratic Republic of the** |
Tungsten | |
Guinea |
Tungsten | |
Indonesia |
Tungsten | |
Laos |
Tungsten | |
Malaysia |
Tungsten | |
Mongolia |
Tungsten | |
Myanmar |
Tungsten | |
Nigeria |
Tungsten | |
Peru |
Tungsten | |
Portugal |
Tungsten | |
Russian Federation |
Tungsten | |
Rwanda** |
Tungsten | |
Spain |
Tungsten | |
Taiwan |
Tungsten | |
Thailand |
Tungsten | |
Uganda** |
Tungsten | |
United Kingdom |
Tungsten | |
United States of America |
Tungsten | |
Uzbekistan |
Tungsten | |
Vietnam |
Tungsten |
* | Minerals from this country were substantially transformed before being incorporated into finished products. Such a substantial transformation of the minerals happened outside of the United States in a third country by a person other than a United States person. |
** | Covered Countries |
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Summary of Smelter and Refiner Status
The charts below summarize, by mineral, the numbers of operational smelter and refiner facilities, identified by our surveyed suppliers, that as of March 3, 2020:
(i) | are conformant to a responsible mineral sourcing validation program (referred to as Conformant), |
(ii) | have begun participating in a responsible mineral sourcing validation program (referred to as Active; as noted above, we have no reason to believe, based on our due diligence, that these facilities process conflict minerals originating from the Covered Countries), or |
(iii) | are not conformant to a responsible mineral sourcing validation program (referred to as Non Conformant; as noted above, we have no reason to believe, based on our due diligence, that this facility processes conflict minerals originating from the Covered Countries). |
Status of Identified Smelters and Refiners
The table below (Table 2) lists the facilities which, to the extent known, processed the necessary conflict minerals in our products based on responses received from our surveyed suppliers as of March 3, 2020. Intel conducts no direct transactions and has no contractual relationship with these smelter and refiner facilities nor their sources of ore.
11
Table 2
Metal |
Smelter or Refinery Facility Name |
Country | ||
Tantalum |
Asaka Riken Co., Ltd.* | JAPAN | ||
Tantalum |
Changsha South Tantalum Niobium Co., Ltd.* | CHINA | ||
Tantalum |
D Block Metals, LLC* | UNITED STATES OF AMERICA | ||
Tantalum |
Exotech Inc.* | UNITED STATES OF AMERICA | ||
Tantalum |
F&X Electro-Materials Ltd.* | CHINA | ||
Tantalum |
FIR Metals & Resource Ltd.* | CHINA | ||
Tantalum |
Global Advanced Metals Aizu* | JAPAN | ||
Tantalum |
Global Advanced Metals Boyertown* | UNITED STATES OF AMERICA | ||
Tantalum |
Guangdong Zhiyuan New Material Co., Ltd.* | CHINA | ||
Tantalum |
H.C. Starck Co., Ltd.* | THAILAND | ||
Tantalum |
H.C. Starck Tantalum and Niobium GmbH* | GERMANY | ||
Tantalum |
H.C. Starck Hermsdorf GmbH* | GERMANY | ||
Tantalum |
H.C. Starck Inc.* | UNITED STATES OF AMERICA | ||
Tantalum |
H.C. Starck Ltd.* | JAPAN | ||
Tantalum |
H.C. Starck Smelting GmbH & Co. KG* | GERMANY | ||
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd.* | CHINA | ||
Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | CHINA | ||
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd.* | CHINA | ||
Tantalum |
Jiujiang Tanbre Co., Ltd.* | CHINA | ||
Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* | CHINA | ||
Tantalum |
KEMET Blue Metals* | MEXICO | ||
Tantalum |
LSM Brasil S.A.* | BRAZIL | ||
Tantalum |
Metallurgical Products India Pvt., Ltd.* | INDIA | ||
Tantalum |
Mineracao Taboca S.A.* | BRAZIL | ||
Tantalum |
Mitsui Mining and Smelting Co., Ltd.* | JAPAN | ||
Tantalum |
NPM Silmet AS* | ESTONIA | ||
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd.* | CHINA | ||
Tantalum |
QuantumClean* | UNITED STATES OF AMERICA | ||
Tantalum |
Resind Industria e Comercio Ltda.* | BRAZIL | ||
Tantalum |
Yanling Jincheng Tantalum & Niobium Co., Ltd.* | CHINA | ||
Tantalum |
Solikamsk Magnesium Works OAO* | RUSSIAN FEDERATION | ||
Tantalum |
Taki Chemical Co., Ltd.* | JAPAN | ||
Tantalum |
Telex Metals* | UNITED STATES OF AMERICA | ||
Tantalum |
Ulba Metallurgical Plant JSC* | KAZAKHSTAN | ||
Tantalum |
XinXing HaoRong Electronic Material Co., Ltd.* | CHINA | ||
Tantalum |
Jiangxi Tuohong New Raw Material* | CHINA | ||
Tantalum |
PRG Dooel* | NORTH MACEDONIA | ||
Tin |
Maanshan Weitai Tin Co., Ltd.* | CHINA | ||
Tin |
Chifeng Dajingzi Tin Industry Co., Ltd.* | CHINA | ||
Tin |
Tin Technology & Refining* | UNITED STATES OF AMERICA | ||
Tin |
Yunnan Yunfan Non-ferrous Metals Co., Ltd.* | CHINA | ||
Tin |
Alpha* | UNITED STATES OF AMERICA |
12
Metal |
Smelter or Refinery Facility Name |
Country | ||
Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | CHINA | ||
Tin |
China Tin Group Co., Ltd.* | CHINA | ||
Tin |
Dowa* | JAPAN | ||
Tin |
Metallo Spain S.L.U.* | SPAIN | ||
Tin |
EM Vinto* | BOLIVIA | ||
Tin |
Fenix Metals* | POLAND | ||
Tin |
Gejiu Kai Meng Industry and Trade LLC* | CHINA | ||
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CHINA | ||
Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.* | CHINA | ||
Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd.* | CHINA | ||
Tin |
Huichang Jinshunda Tin Co., Ltd.* | CHINA | ||
Tin |
Magnus Minerais Metais e Ligas Ltda.* | BRAZIL | ||
Tin |
Malaysia Smelting Corporation (MSC)* | MALAYSIA | ||
Tin |
Melt Metais e Ligas S.A.* | BRAZIL | ||
Tin |
Metallic Resources, Inc.* | UNITED STATES OF AMERICA | ||
Tin |
Metallo Belgium N.V.* | BELGIUM | ||
Tin |
Mineracao Taboca S.A.* | BRAZIL | ||
Tin |
Minsur* | PERU | ||
Tin |
Mitsubishi Materials Corporation* | JAPAN | ||
Tin |
O.M. Manufacturing (Thailand) Co., Ltd.* | THAILAND | ||
Tin |
O.M. Manufacturing Philippines, Inc.* | PHILIPPINES | ||
Tin |
Operaciones Metalurgicas S.A.* | BOLIVIA | ||
Tin |
PT Artha Cipta Langgeng* | INDONESIA | ||
Tin |
PT ATD Makmur Mandiri Jaya* | INDONESIA | ||
Tin |
PT Mitra Stania Prima* | INDONESIA | ||
Tin |
PT Refined Bangka Tin* | INDONESIA | ||
Tin |
PT Timah Tbk Kundur* | INDONESIA | ||
Tin |
PT Timah Tbk Mentok* | INDONESIA | ||
Tin |
Resind Industria e Comercio Ltda.* | BRAZIL | ||
Tin |
Rui Da Hung* | TAIWAN | ||
Tin |
Soft Metais Ltda.* | BRAZIL | ||
Tin |
Thaisarco* | THAILAND | ||
Tin |
White Solder Metalurgia e Mineracao Ltda.* | BRAZIL | ||
Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.* | CHINA | ||
Tin |
Yunnan Tin Company Limited* | CHINA | ||
Tin |
Thai Nguyen Mining and Metallurgy Co., Ltd.* | VIETNAM | ||
Tin |
HuiChang Hill Tin Industry Co., Ltd.* | CHINA | ||
Tin |
Guanyang Guida Nonferrous Metal Smelting Plant* | CHINA | ||
Tin |
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* | CHINA | ||
Tin |
Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA | ||
Gold |
DS PRETECH Co., Ltd.* | KOREA, REPUBLIC OF | ||
Gold |
Eco-System Recycling Co., Ltd. West Plant* | JAPAN | ||
Gold |
Eco-System Recycling Co., Ltd. North Plant* | JAPAN | ||
Gold |
8853 S.p.A.* | ITALY | ||
Gold |
Advanced Chemical Company* | UNITED STATES OF AMERICA |
13
Metal |
Smelter or Refinery Facility Name |
Country | ||
Gold |
Aida Chemical Industries Co., Ltd.* | JAPAN | ||
Gold |
Al Etihad Gold Refinery DMCC* | UNITED ARAB EMIRATES | ||
Gold |
Allgemeine Gold-und Silberscheideanstalt A.G.* | GERMANY | ||
Gold |
Almalyk Mining and Metallurgical Complex (AMMC)* | UZBEKISTAN | ||
Gold |
AngloGold Ashanti Corrego do Sitio Mineracao* | BRAZIL | ||
Gold |
Argor-Heraeus S.A.* | SWITZERLAND | ||
Gold |
Asahi Pretec Corp.* | JAPAN | ||
Gold |
Asahi Refining Canada Ltd.* | CANADA | ||
Gold |
Asahi Refining USA Inc.* | UNITED STATES OF AMERICA | ||
Gold |
Asaka Riken Co., Ltd.* | JAPAN | ||
Gold |
Aurubis AG* | GERMANY | ||
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | PHILIPPINES | ||
Gold |
Boliden AB* | SWEDEN | ||
Gold |
C. Hafner GmbH + Co. KG* | GERMANY | ||
Gold |
CCR RefineryGlencore Canada Corporation* | CANADA | ||
Gold |
Cendres + Metaux S.A.* | SWITZERLAND | ||
Gold |
Chimet S.p.A.* | ITALY | ||
Gold |
Chugai Mining* | JAPAN | ||
Gold |
Daye Non-Ferrous Metals Mining Ltd.* | CHINA | ||
Gold |
DSC (Do Sung Corporation)* | KOREA, REPUBLIC OF | ||
Gold |
DODUCO Contacts and Refining GmbH* | GERMANY | ||
Gold |
Dowa* | JAPAN | ||
Gold |
Eco-System Recycling Co., Ltd. East Plant* | JAPAN | ||
Gold |
Emirates Gold DMCC* | UNITED ARAB EMIRATES | ||
Gold |
Geib Refining Corporation* | UNITED STATES OF AMERICA | ||
Gold |
LT Metal Ltd.* | KOREA, REPUBLIC OF | ||
Gold |
Heimerle + Meule GmbH* | GERMANY | ||
Gold |
Heraeus Metals Hong Kong Ltd.* | CHINA | ||
Gold |
Heraeus Precious Metals GmbH & Co. KG* | GERMANY | ||
Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | CHINA | ||
Gold |
Ishifuku Metal Industry Co., Ltd.* | JAPAN | ||
Gold |
Istanbul Gold Refinery* | TURKEY | ||
Gold |
Italpreziosi* | ITALY | ||
Gold |
Japan Mint* | JAPAN | ||
Gold |
Jiangxi Copper Co., Ltd.* | CHINA | ||
Gold |
JSC Uralelectromed* | RUSSIAN FEDERATION | ||
Gold |
JX Nippon Mining & Metals Co., Ltd.* | JAPAN | ||
Gold |
Kazzinc* | KAZAKHSTAN | ||
Gold |
Kennecott Utah Copper LLC* | UNITED STATES OF AMERICA | ||
Gold |
KGHM Polska Miedz Spolka Akcyjna* | POLAND | ||
Gold |
Kojima Chemicals Co., Ltd.* | JAPAN | ||
Gold |
Korea Zinc Co., Ltd.* | KOREA, REPUBLIC OF | ||
Gold |
Kyrgyzaltyn JSC* | KYRGYZSTAN | ||
Gold |
LOrfebre S.A.* | ANDORRA |
14
Metal |
Smelter or Refinery Facility Name |
Country | ||
Gold |
LS-NIKKO Copper Inc.* | KOREA, REPUBLIC OF | ||
Gold |
Marsam Metals* | BRAZIL | ||
Gold |
Materion* | UNITED STATES OF AMERICA | ||
Gold |
Matsuda Sangyo Co., Ltd.* | JAPAN | ||
Gold |
Metalor Technologies (Hong Kong) Ltd.* | CHINA | ||
Gold |
Metalor Technologies (Singapore) Pte., Ltd.* | SINGAPORE | ||
Gold |
Metalor Technologies (Suzhou) Ltd.* | CHINA | ||
Gold |
Metalor Technologies S.A.* | SWITZERLAND | ||
Gold |
Metalor USA Refining Corporation* | UNITED STATES OF AMERICA | ||
Gold |
Metalurgica Met-Mex Penoles S.A. De C.V.* | MEXICO | ||
Gold |
Mitsubishi Materials Corporation* | JAPAN | ||
Gold |
Mitsui Mining and Smelting Co., Ltd.* | JAPAN | ||
Gold |
MMTC-PAMP India Pvt., Ltd.* | INDIA | ||
Gold |
Moscow Special Alloys Processing Plant* | RUSSIAN FEDERATION | ||
Gold |
Nadir Metal Rafineri San. Ve Tic. A.S.* | TURKEY | ||
Gold |
Navoi Mining and Metallurgical Combinat* | UZBEKISTAN | ||
Gold |
Nihon Material Co., Ltd.* | JAPAN | ||
Gold |
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | AUSTRIA | ||
Gold |
Ohura Precious Metal Industry Co., Ltd.* | JAPAN | ||
Gold |
OJSC The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastsvetmet)* | RUSSIAN FEDERATION | ||
Gold |
OJSC Novosibirsk Refinery* | RUSSIAN FEDERATION | ||
Gold |
PAMP S.A.* | SWITZERLAND | ||
Gold |
Prioksky Plant of Non-Ferrous Metals* | RUSSIAN FEDERATION | ||
Gold |
PT Aneka Tambang (Persero) Tbk* | INDONESIA | ||
Gold |
PX Precinox S.A.* | SWITZERLAND | ||
Gold |
Rand Refinery (Pty) Ltd.* | SOUTH AFRICA | ||
Gold |
REMONDIS PMR B.V.* | NETHERLANDS | ||
Gold |
Royal Canadian Mint* | CANADA | ||
Gold |
SAAMP* | FRANCE | ||
Gold |
Samduck Precious Metals* | KOREA, REPUBLIC OF | ||
Gold |
SAXONIA Edelmetalle GmbH* | GERMANY | ||
Gold |
SEMPSA Joyeria Plateria S.A.* | SPAIN | ||
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | CHINA | ||
Gold |
Sichuan Tianze Precious Metals Co., Ltd.* | CHINA | ||
Gold |
Singway Technology Co., Ltd.* | TAIWAN | ||
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals* | RUSSIAN FEDERATION | ||
Gold |
Solar Applied Materials Technology Corp.* | TAIWAN | ||
Gold |
Sumitomo Metal Mining Co., Ltd.* | JAPAN | ||
Gold |
T.C.A S.p.A* | ITALY | ||
Gold |
Tanaka Kikinzoku Kogyo K.K.* | JAPAN | ||
Gold |
Great Wall Precious Metals Co., Ltd. of CBPM* | CHINA | ||
Gold |
The Refinery of Shandong Gold Mining Co., Ltd.* | CHINA | ||
Gold |
Tokuriki Honten Co., Ltd.* | JAPAN |
15
Metal |
Smelter or Refinery Facility Name |
Country | ||
Gold |
Torecom* | KOREA, REPUBLIC OF | ||
Gold |
Umicore Brasil Ltda.* | BRAZIL | ||
Gold |
Umicore Precious Metals Thailand* | THAILAND | ||
Gold |
Umicore S.A. Business Unit Precious Metals Refining* | 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 |
WIELAND Edelmetalle GmbH* | GERMANY | ||
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 |
AU Traders and Refiners* | SOUTH AFRICA | ||
Gold |
Bangalore Refinery* | INDIA | ||
Gold |
SungEel HiMetal Co., Ltd.* | KOREA, REPUBLIC OF | ||
Gold |
Planta Recuperadora de Metales SpA* | CHILE | ||
Gold |
Safimet S.p.A* | ITALY | ||
Gold |
SAFINA A.S.** | CZECH REPUBLIC | ||
Tungsten |
KGETS Co., Ltd.* | KOREA, REPUBLIC OF | ||
Tungsten |
Lianyou Metals Co., Ltd.* | TAIWAN | ||
Tungsten |
A.L.M.T. Corp.* | JAPAN | ||
Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd.* | CHINA | ||
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd.* | CHINA | ||
Tungsten |
Fujian Jinxin Tungsten Co., Ltd.* | CHINA | ||
Tungsten |
Ganzhou Haichuang 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 |
H.C. Starck Smelting GmbH & Co. KG* | GERMANY | ||
Tungsten |
Hunan Chenzhou Mining Co., Ltd.* | CHINA | ||
Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd.* | CHINA | ||
Tungsten |
Hydrometallurg, JSC* | RUSSIAN FEDERATION | ||
Tungsten |
Japan New Metals Co., Ltd.* | JAPAN | ||
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | CHINA | ||
Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd.* | CHINA | ||
Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | CHINA | ||
Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | CHINA | ||
Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd.* | CHINA | ||
Tungsten |
Kennametal Huntsville* | UNITED STATES OF AMERICA | ||
Tungsten |
Malipo Haiyu Tungsten Co., Ltd.* | CHINA | ||
Tungsten |
Niagara Refining LLC* | UNITED STATES OF AMERICA | ||
Tungsten |
Masan Tungsten Chemical LLC (MTC)* | VIETNAM | ||
Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd.* | VIETNAM |
16
Metal |
Smelter or Refinery Facility Name |
Country | ||
Tungsten |
Wolfram Bergbau und Hutten AG* | AUSTRIA | ||
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd.* | CHINA | ||
Tungsten |
Xiamen Tungsten Co., Ltd.* | CHINA | ||
Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd.* | CHINA | ||
Tungsten |
Philippine Chuangxin Industrial Co., Inc.* | PHILIPPINES | ||
Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.* | CHINA | ||
Tungsten |
Hunan Litian Tungsten Industry Co., Ltd.* | CHINA | ||
Tungsten |
Jiangxi Xianglu Tungsten Co., Ltd.** | CHINA |
| Smelter and refiner facility names and locations as reported by the RMI as of March 3, 2020. |
* | Denotes smelters and refiners which are conformant to a responsible mineral sourcing validation program as of March 3, 2020. |
** | Denotes smelters and refiners which are participating in a responsible mineral sourcing validation program as of March 3, 2020. |
Conclusion and Future Due Diligence Measures
The facilities reported in Table 2 processed the necessary conflict minerals in our products based on responses received from 96% of our surveyed suppliers as of March 3, 2020. As of March 3, 2020, 99.6% of the reported smelter and refiner facilities are conformant or are participating in a responsible mineral sourcing validation program. Based on our due diligence, we have no reason to believe the sole remaining facility sources conflict minerals from the Covered Countries, and we are working to remove this facility from our supply chain. All smelters and refiners that we know or have reason to believe may source conflict minerals from the Covered Countries which may not be solely from recycled or scrap sources are conformant to a responsible mineral sourcing validation program as of March 3, 2020. We have no reason to believe that any of the reported smelter and refiner facilities directly or indirectly finance or benefit armed groups in the Covered Countries. We are continuing to engage in the activities described above in Design of Responsible Minerals Program and we are continuing to follow up with suppliers that are not meeting our requirements as well as contacting smelters and refiners that are not yet conformant to a responsible mineral sourcing validation program. We are encouraging and assisting such smelters and refiners to participate in a responsible mineral sourcing validation program, thus supporting our efforts to build ethical and socially responsible supply chains for our company.
Our efforts to determine the mine or location of origin of the necessary conflict minerals in all our products with the greatest possible specificity consisted of the due diligence measures described in this Report. In particular, we relied on the information made available by responsible mineral sourcing validation programs for the smelters and refiners in our supply chain because such programs review and audit whether sufficient evidence exists regarding the mine and/or location of origin of the conflict minerals that the audited smelter or refiner facilities have processed. We also sought source and chain of custody information directly from smelters and refiners and from publicly available sources and, if we determined such information to be reliable, we used the information to make reasonable conclusions on the source and chain of custody of the conflict minerals processed by facilities which were not conformant to or participating in a responsible mineral sourcing validation program.
Additionally, Intels responsible minerals program is evolving to address a broader range of minerals originating from CAHRAs. We are assessing the risks of other minerals in our products and have updated our due diligence practices to address CAHRAs when conducting country of origin analysis in our supply chain. We also have updated our minerals sourcing policy to reflect this expansion in scope. Intel is continuing to partner with the RMI and other key industry associations to expand and improve responsible mineral sourcing.
Efforts Pertaining to Cobalt
Intel continues to evaluate and expand upon the framework of our due diligence programs as material use and risk profiles emerge. Cobalt has been identified as a mineral of concern due to reports of child labor and other social impacts in CAHRAs. Aligned with our approach to conflict minerals, our desire is not to eliminate sourcing from CAHRAs, but rather to identify and mitigate risks in our supply chain to obtain only minerals that are sourced responsibly.
17
We use cobalt in our next-generation microprocessor manufacturing technology and have taken steps to pursue its responsible sourcing. Since 2017, we have conducted a survey of our direct suppliers that provide materials contributing cobalt to Intel-manufactured microprocessor products to identify cobalt smelters and refiners in our microprocessor supply chain and have reported our results in our Corporate Responsibility Report. We conducted risk mitigation in our supply chain, including smelter outreach, which included a visit to one cobalt refiner in 2019, and country of origin assessments, as well as working with direct suppliers to facilitate alternative sourcing where appropriate.
In 2019, Intel began using the newly established RMI-developed Cobalt Reporting Template (CRT) and expanded the survey process to include suppliers of product components in addition to our manufactured products. We identified and surveyed 55 suppliers whose products may contain intentionally added cobalt contributing to our in-scope products. Out of these 55 surveyed suppliers, 44 responded with a completed CRT and another four submitted a timeline for completion to give us an 87% overall response rate. We will continue to work on education and capability building with our suppliers to improve our response rate and data accuracy. We are using the information obtained to conduct due diligence on the identified refiners and actively focus our outreach efforts to encourage RMAP involvement. Participation in such a program verifies these facilities have management systems in place to ensure the cobalt they process is responsibly sourced in alignment with OECD Guidance.
Intel strongly believes that collaboration among industry, government, non-governmental organizations and civil society experts is the best way to effectively create positive change in our supply chain. Intel is participating in developing industry-wide standards to better align, and thus strengthen, the collective approach to responsible cobalt sourcing. Accordingly, we collaborated with RMI to establish industry standards, including the Cobalt Reporting Template (CRT) and the RMAP Pilot Cobalt Due Diligence Standard. These efforts further our pursuit to ensure that cobalt in our products is responsibly sourced.
On our website at www.intel.com/conflictfree, we publish a smelter and refiner list that includes the facilities that, to the extent known, may have processed the cobalt in our products based on responses received from our surveyed suppliers.
Independent Private Sector Audit of this Report
We obtained an independent private sector audit of the conflict minerals assertions contained in the Design of Conflict Minerals Program and Description of Due Diligence Measures Performed sections in this Report by Ernst & Young LLP, which is set forth as Exhibit A to this Report. The Efforts Pertaining to Cobalt section is excluded from the private sector audit in this Report.
Intel and the Intel logo, Intel Atom, Intel Core, Xeon, Celeron, Pentium, Quark, Stratix, Arria, Cyclone, MAX, Agilex, eASIC, and Enpirion are trademarks of Intel Corporation or its subsidiaries in the U.S. and/or other countries.
Other names and brands may be claimed as the property of others. The Efforts Pertaining to Cobalt section is not required by the Rule and is furnished as a supplement to this Report.
18
Exhibit A
Report of Independent Accountants
To the stockholders and The Board of Directors of Intel Corporation
We have examined whether the design of Intel Corporations (the Company) due diligence framework as set forth in the Design of Responsible Minerals Program section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2019, is in conformity, in all material respects, with the criteria set forth in the Organisation of 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 Due Diligence Guidance), and whether the Companys description of the due diligence measures it performed, as set forth in Description of Due Diligence Measures Performed section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2019, is consistent, in all material respects, 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. Our responsibility is to express an opinion on the design of the Companys due diligence framework and on the description of the due diligence measures the Company performed, based on our examination. Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards applicable to attestation engagements contained in Government Auditing Standards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Companys due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our opinion. Our examination was not conducted for the purpose of evaluating:
| 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 |
Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than the design of the Companys due diligence framework as set forth in the Design of Responsible Minerals Program section and the Companys description of the due diligence measures it performed as set forth in the Description of Due Diligence Measures Performed section referenced in the first paragraph above.
In our opinion, the design of the Companys due diligence framework for the reporting period from January 1 to December 31, 2019, as set forth in the Design of Responsible Minerals Program section of the Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and the Companys description of the due diligence measures it performed as set forth in the Description of Due Diligence Measures Performed section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2019, is consistent, in all material respects, with the due diligence process that the Company undertook.
/s/ Ernst & Young LLP
San Jose, California
May 14, 2020
19