Exhibit 1.01

CONFLICT MINERALS REPORT

 

LOGO

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, 2020 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 “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 Intel’s 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. Intel’s responsible minerals program continues to expand in scope to include additional minerals, such as cobalt, and we have taken initial steps to include aluminum, copper, nickel, and silver in the next phase of our program. We also continue 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, Intel is electing to also describe the proactive due diligence we began several years ago around cobalt as well as Intel’s public goal to responsibly source additional minerals used in semiconductor manufacturing. In May of 2020, we released Intel’s annual Corporate Responsibility Report, which established a new 2030 strategy and goals for continued progress for the next decade in multiple areas of corporate responsibility, including responsible minerals sourcing. An overview of this initiative and the practical steps to be taken to responsibly source beyond conflict minerals is described in a separate section below.

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 and to not negatively affect the economies of such countries.

 

1


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 (NGOs), 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. 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 Association’s International Tin Supply Chain Initiative (iTSCi), including answering a call to provide COVID-19 related emergency funding to help ensure its efforts to promote responsible in-region sourcing and assurance continued without interruption. Intel also holds a leadership position in the Public-Private Alliance for Responsible Minerals Trade (PPA), which promotes 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).

In late 2019, Intel participated in a delegation organized by the PPA with NGOs, U.S. Government representatives, and other technology companies to visit the DRC and neighboring Rwanda to observe and discuss challenges faced in the mining industry. A key takeaway from this experience was the need for companies to increase upstream program support to ensure the sustainability and improve the livelihoods of the most vulnerable communities tied to our supply chain. Following this approach, Intel has developed a more comprehensive program to partner with our peers and vetted NGOs to increase mining community support as a complement to our due diligence program. A few examples of projects supported by Intel in 2020 are City of Joy (via the PPA), a group providing health care, education, and holistic rehabilitation to survivors of gender violence in Congolese mining communities; Congo Power, an alliance providing mining areas with clean power; and the PACT-RMI Youth Vocational Training Program, a program aimed at providing mining alternatives to Congolese youths. We believe that maintaining a connection and providing support to the communities that serve our vast global supply chain is a crucial complement to our responsible minerals program and we plan to continue incorporating this practice into our long-term strategy.

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 the following:

 

   

Our microprocessor and chipset products, such as our Intel® Core, Intel® Xeon®, and Intel Atom® processors

 

   

Our accelerator products, such as our FPGA products, Mobileye EyeQ® system-on-chip products, and Habana® AI accelerators

 

   

Our boards and systems products, such as our Intel® NUCs

 

   

Our connectivity products, such as our Intel® Tofino Ethernet switch ASICs and silicon photonics products

 

   

Our memory and storage products, such as our SSD, persistent memory, and memory component 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.

 

2


Design of Responsible Minerals Program

The design of Intel’s 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 (GSC) to implement our Responsible Minerals Sourcing Policy. We review such efforts with our Chief Executive Officer (CEO) and senior management of GSC.

 

   

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 and 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 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.

 

3


   

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 RMI’s Responsible Minerals Assurance Program (RMAP), and other RMI cross-recognized, independent third-party audit programs. Information regarding RMAP as well as a list of RMI cross-recognized, independent third-party audit programs can be found on the RMI’s website: http://www.responsiblemineralsinitiative.org/minerals-due-diligence/recognized-standards-or-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. In cases where physical visitation is not possible, such as during the COVID-19 pandemic, smelter and refiner due diligence may be conducted virtually where appropriate.

 

  3.

Execute a strategy to respond to identified risks:

 

   

Report findings to senior management: Provide progress reports to our CEO and GSC 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.

 

   

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 RMI’s 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 the RMI.

 

  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 “Intel’s Efforts to Achieve a Responsibly Sourced Mineral Supply Chain” and Corporate Responsibility Report available on our company website at www.intel.com/conflictfree.

 

4


   

Obtain an independent private sector audit of applicable sections of our Report and file a Form SD annually with the SEC. This information is publicly available on our company website at www.intel.com/conflictfree. After consultation with stakeholders, including external NGOs and internal management, we concluded that a reduced frequency of private sector audits would continue to meet stakeholder objectives while also enabling us to redeploy resources to upstream projects and program expansion.

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 2020, 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. RMAP and RMI cross-recognized programs provided country of origin data for conformant smelters and refiners, including on an aggregate basis in certain cases. We also proactively attempted to contact smelter and refiner facilities identified by our surveyed suppliers that were not conformant to a responsible mineral sourcing validation program and requested each facility contacted to identify 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 2020, Intel conducted a supply chain survey of 158 suppliers that we determined may contribute necessary conflict minerals to our products.

The results of our RCOI as of March 1, 2021 are as follows:

 

   

96% of surveyed suppliers provided a CMRT in response to our supply chain survey request.

 

   

The surveyed suppliers identified 231 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 at least 47 of these 231 smelters and refiners may have originated in the Covered Countries and may not be solely from recycled or scrap sources.

Of the 158 surveyed suppliers, 53 were suppliers specific to Mobileye, an Intel subsidiary, that were not otherwise part of the Intel supply chain (“Mobileye-unique” suppliers). Our response rate excluding Mobileye-unique suppliers was 100%. Intel’s supplier due diligence with non-responsive Mobileye-unique suppliers is ongoing and we are continuing work on our escalation paths to increase the response rate, including pursuing alternate sourcing.

Conclusion Based on Reasonable Country of Origin Inquiry

We have concluded in good faith that during 2020:

 

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.

 

5


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 1, 2021, 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.

 

   

Provided five progress reports to GSC senior management and two progress reports to our CEO that summarized the status of our responsible minerals program.

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 any of 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.

 

6


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 28 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 supplier’s 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. 24 of these 28 surveyed suppliers provided an updated CMRT which we determined, using the same evaluation criteria, to be complete and accurate. We continue to work on capacity building with the remaining suppliers (which are all Mobileye-unique suppliers) 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 action items that 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 97% of the surveyed suppliers that had provided a CMRT as of March 1, 2021 (148 out of 152) are in compliance with our Responsible Minerals Sourcing Policy or contractual requirements. We continue to work with the remaining four Mobileye-unique suppliers to drive compliance.

Smelter and Refiner Due Diligence Results

As of March 1, 2021, an aggregate of 231 operational smelters and refiners were identified by our surveyed suppliers as facilities that may process the necessary conflict minerals contained in the products these surveyed suppliers provided to Intel.

Intel conducted due diligence on the smelters and refiners reported during our survey process. 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.

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. Due to COVID-19 safety concerns associated with travel, Intel virtually conducted all direct outreach to smelters and refiners to encourage and assist their participation in a third-party audit program. Additionally, we increased the breadth of our virtual outreach activity to smelters and refiners already participating in a third-party audit program to ensure participation continuity, minimize disruption, and provide additional support throughout the pandemic. 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.

 

7


During this reporting year, we identified 10 smelter and refiner facilities reported in our supply chain 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 1, 2021:

 

   

5 of these 10 smelter and refiner facilities had later become conformant to a responsible mineral sourcing program.

 

   

2 of these 10 smelter and refiner facilities have begun participating in a responsible mineral sourcing validation program but are not yet conformant. Based on Intel’s due diligence, we have no reason to believe these facilities sourced conflict minerals from the Covered Countries.

 

   

The remaining 3 facilities decided not to continue participating in a responsible mineral sourcing program. Intel has successfully achieved removal of these smelters and refiners from our supply chain.

As result of our due diligence activities summarized above, we determined the following as of March 1, 2021:

 

   

All 231 smelters and refiners identified by our surveyed suppliers are either conformant to a responsible mineral sourcing validation program or have begun participating in such a program.

 

   

All 47 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 231 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 1, 2021 as a result of our due diligence activities:

Table 1

 

Country of Origin

   Mineral
Angola**          Tin   
Argentina    Gold       Tin   
Australia    Gold    Tantalum    Tin    Tungsten
Austria       Tantalum    Tin    Tungsten
Azerbaijan    Gold         
Bangladesh          Tin   
Belarus       Tantalum    Tin   
Belgium          Tin    Tungsten
Benin    Gold       Tin   
Bolivia    Gold    Tantalum    Tin    Tungsten
Botswana    Gold         
Brazil    Gold    Tantalum    Tin    Tungsten
Bulgaria          Tin   
Burkina Faso    Gold         
Burundi**       Tantalum    Tin    Tungsten
Canada    Gold       Tin    Tungsten
Chile    Gold       Tin   
China    Gold    Tantalum    Tin    Tungsten
Colombia    Gold    Tantalum    Tin    Tungsten
Costa Rica    Gold         
Cote d’Ivoire    Gold         
Croatia          Tin   
Cuba*    Gold         
Cyprus    Gold       Tin   

 

8


Country of Origin

   Mineral
Czechia          Tin    Tungsten
Democratic Republic of the Congo**    Gold    Tantalum    Tin    Tungsten
Denmark          Tin   
Dominican Republic    Gold         
Ecuador    Gold         
Egypt    Gold       Tin   
El Salvador          Tin   
Eritrea    Gold         
Estonia          Tin   
Ethiopia    Gold    Tantalum      
Fiji    Gold         
Finland    Gold       Tin   
France       Tantalum    Tin    Tungsten
French Guiana    Gold         
Gabon          Tin   
Georgia    Gold         
Germany       Tantalum    Tin    Tungsten
Ghana    Gold       Tin   
Greece          Tin   
Guatemala    Gold         
Guinea    Gold       Tin   
Guyana    Gold         
Honduras    Gold         
Hong Kong          Tin    Tungsten
Hungary          Tin   
India       Tantalum    Tin   
Indonesia    Gold    Tantalum    Tin   
Iran*    Gold         
Ireland       Tantalum    Tin   
Israel       Tantalum    Tin   
Italy          Tin   
Japan    Gold    Tantalum    Tin    Tungsten
Jordan          Tin   
Kazakhstan    Gold       Tin    Tungsten
Kenya    Gold         
Laos    Gold       Tin   
Latvia          Tin    Tungsten
Lebanon          Tin   
Liberia    Gold         
Libya          Tin   
Lithuania          Tin   
Luxembourg          Tin   
Madagascar       Tantalum      
Malaysia    Gold    Tantalum    Tin    Tungsten
Mali    Gold         
Malta          Tin   
Mauritania    Gold         
Mexico    Gold       Tin    Tungsten
Mongolia    Gold       Tin    Tungsten
Morocco    Gold       Tin   
Mozambique    Gold    Tantalum      
Myanmar       Tantalum    Tin    Tungsten
Namibia    Gold    Tantalum      
Netherlands    Gold       Tin   

 

9


Country of Origin

   Mineral
New Zealand    Gold       Tin   
Nicaragua    Gold         
Niger    Gold         
Nigeria       Tantalum    Tin    Tungsten
Norway          Tin   
Pakistan          Tin   
Papua New Guinea    Gold         
Peru    Gold       Tin    Tungsten
Philippines    Gold       Tin   
Poland          Tin   
Portugal          Tin    Tungsten
Puerto Rico    Gold       Tin   
Qatar          Tin   
Romania          Tin   
Russia    Gold    Tantalum    Tin    Tungsten
Rwanda**    Gold    Tantalum    Tin    Tungsten
Saudi Arabia    Gold       Tin   
Senegal    Gold       Tin   
Serbia    Gold         
Sierra Leone       Tantalum      
Singapore          Tin   
Slovakia    Gold       Tin   
Slovenia          Tin   
Solomon Islands    Gold         
Somaliland       Tantalum      
South Africa    Gold       Tin   
South Korea       Tantalum    Tin   
Spain    Gold    Tantalum    Tin    Tungsten
Sudan          Tin   
Suriname    Gold         
Swaziland    Gold         
Sweden    Gold       Tin   
Switzerland       Tantalum    Tin   
Taiwan          Tin    Tungsten
Tajikistan    Gold         
Tanzania**    Gold       Tin   
Thailand       Tantalum    Tin    Tungsten
Togo          Tin   
Tunisia          Tin   
Turkey    Gold       Tin   
Uganda**    Gold    Tantalum    Tin    Tungsten
Ukraine          Tin   
United Arab Emirates          Tin    Tungsten
United Kingdom    Gold    Tantalum    Tin    Tungsten
United States of America    Gold    Tantalum    Tin    Tungsten
Uruguay    Gold       Tin   
Uzbekistan             Tungsten
Venezuela*          Tin   
Vietnam          Tin    Tungsten
Yemen          Tin   
Zambia**    Gold         
Zimbabwe    Gold    Tantalum       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

 

10


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 1, 2021:

 

  (i)

are conformant to a responsible mineral sourcing validation program (referred to as “Conformant”), or

 

  (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)

Status of Identified Smelters and Refiners

 

LOGO

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 1, 2021. Intel conducts no direct transactions and has no contractual relationship with these smelter and refiner facilities nor their sources of ore.

 

11


Table 2

 

Mineral

  

Smelter or Refinery Facility Name

  

Country

Gold

   8853 S.p.A.*    ITALY

Gold

   Advanced Chemical Company*    UNITED STATES OF AMERICA

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

   AU Traders and Refiners*    SOUTH AFRICA

Gold

   Aurubis AG*    GERMANY

Gold

   Bangalore Refinery*    INDIA

Gold

   Bangko Sentral ng Pilipinas (Central Bank of the Philippines)*    PHILIPPINES

Gold

   Boliden AB*    SWEDEN

Gold

   C. Hafner GmbH + Co. KG*    GERMANY

Gold

   CCR Refinery—Glencore 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

   DODUCO Contacts and Refining GmbH*    GERMANY

Gold

   Dowa*    JAPAN

Gold

   DSC (Do Sung Corporation)*    SOUTH KOREA

Gold

   Eco-System Recycling Co., Ltd. East Plant*    JAPAN

Gold

   Eco-System Recycling Co., Ltd. North Plant*    JAPAN

Gold

   Eco-System Recycling Co., Ltd. West Plant*    JAPAN

Gold

   Emirates Gold DMCC*    UNITED ARAB EMIRATES

Gold

   Geib Refining Corporation*    UNITED STATES OF AMERICA

Gold

   Gold Refinery of Zijin Mining Group Co., Ltd.*    CHINA

Gold

   Great Wall Precious Metals Co., Ltd. of CBPM*    CHINA

Gold

   Heimerle + Meule GmbH*    GERMANY

Gold

   Heraeus Germany GmbH Co. KG**    GERMANY

Gold

   Heraeus Metals Hong Kong Ltd.*    CHINA

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 Novosibirsk Refinery*    RUSSIA

Gold

   JSC Uralelectromed*    RUSSIA

Gold

   JX Nippon Mining & Metals Co., Ltd.*    JAPAN

Gold

   Kazzinc*    KAZAKHSTAN

Gold

   Kennecott Utah Copper LLC*    UNITED STATES OF AMERICA

 

12


Mineral

 

Smelter or Refinery Facility Name

  

Country

Gold

  KGHM Polska Miedz Spolka Akcyjna*    POLAND

Gold

  Kojima Chemicals Co., Ltd.*    JAPAN

Gold

  Korea Zinc Co., Ltd.*    SOUTH KOREA

Gold

  Kyrgyzaltyn JSC*    KYRGYZSTAN

Gold

  L’Orfebre S.A.*    ANDORRA

Gold

  LS-NIKKO Copper Inc.*    SOUTH KOREA

Gold

  LT Metal Ltd.*    SOUTH KOREA

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*    RUSSIA

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)*
   RUSSIA

Gold

  PAMP S.A.*    SWITZERLAND

Gold

  Planta Recuperadora de Metales SpA*    CHILE

Gold

  Prioksky Plant of Non-Ferrous Metals*    RUSSIA

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

  Safimet S.p.A*    ITALY

Gold

  SAFINA A.S.*    CZECHIA

Gold

  Samduck Precious Metals*    SOUTH KOREA

Gold

  SAXONIA Edelmetalle GmbH*    GERMANY

Gold

  SEMPSA Joyeria Plateria S.A.*    SPAIN

Gold

  Shandong Gold Smelting Co., Ltd.*    CHINA

Gold

  Shandong Zhaojin Gold & Silver Refinery Co., Ltd.*    CHINA

Gold

  Sichuan Tianze Precious Metals Co., Ltd.*    CHINA

 

13


Mineral

  

Smelter or Refinery Facility Name

  

Country

Gold

   Singway Technology Co., Ltd.*    TAIWAN

Gold

   SOE Shyolkovsky Factory of Secondary Precious Metals*    RUSSIA

Gold

   Solar Applied Materials Technology Corp.*    TAIWAN

Gold

   Sumitomo Metal Mining Co., Ltd.*    JAPAN

Gold

   SungEel HiMetal Co., Ltd.*    SOUTH KOREA

Gold

   T.C.A S.p.A*    ITALY

Gold

   Tanaka Kikinzoku Kogyo K.K.*    JAPAN

Gold

   Tokuriki Honten Co., Ltd.*    JAPAN

Gold

   TOO Tau-Ken-Altyn*    KAZAKHSTAN

Gold

   Torecom*    SOUTH KOREA

Gold

   TSK Pretech*    SOUTH KOREA

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

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

   H.C. Starck Hermsdorf GmbH*    GERMANY

Tantalum

   H.C. Starck Inc.*    UNITED STATES OF AMERICA

Tantalum

   Hengyang King Xing Lifeng New Materials Co., Ltd.*    CHINA

Tantalum

   Jiangxi Dinghai Tantalum & Niobium Co., Ltd.*    CHINA

Tantalum

   Jiangxi Tuohong New Raw Material*    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 de Mexico*    MEXICO

Tantalum

   LSM Brasil S.A.*    BRAZIL

Tantalum

   Meta Materials*    NORTH MACEDONIA

Tantalum

   Metallurgical Products India Pvt., Ltd.*    INDIA

Tantalum

   Mineracao Taboca S.A.*    BRAZIL

Tantalum

   Mitsui Mining and Smelting Co., Ltd.*    JAPAN

 

14


Mineral

  

Smelter or Refinery Facility Name

  

Country

Tantalum

   Ningxia Orient Tantalum Industry Co., Ltd.*    CHINA

Tantalum

   NPM Silmet AS*    ESTONIA

Tantalum

   QuantumClean*    UNITED STATES OF AMERICA

Tantalum

   Resind Industria e Comercio Ltda.*    BRAZIL

Tantalum

   Solikamsk Magnesium Works OAO*    RUSSIA

Tantalum

   Taki Chemical Co., Ltd.*    JAPAN

Tantalum

   TANIOBIS Co., Ltd.*    THAILAND

Tantalum

   TANIOBIS GmbH*    GERMANY

Tantalum

   TANIOBIS Japan Co., Ltd.*    JAPAN

Tantalum

   TANIOBIS Smelting GmbH & Co. KG*    GERMANY

Tantalum

   Telex Metals*    UNITED STATES OF AMERICA

Tantalum

   Ulba Metallurgical Plant JSC*    KAZAKHSTAN

Tantalum

   XIMEI RESOURCES (GUANGDONG) LIMITED*    CHINA

Tantalum

   XinXing HaoRong Electronic Material Co., Ltd.*    CHINA

Tantalum

   Yanling Jincheng Tantalum & Niobium Co., Ltd.*    CHINA

Tin

   Alpha*    UNITED STATES OF AMERICA

Tin

   Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.*    CHINA

Tin

   Chifeng Dajingzi Tin Industry Co., Ltd.*    CHINA

Tin

   China Tin Group Co., Ltd.*    CHINA

Tin

   Dowa*    JAPAN

Tin

   EM Vinto*    BOLIVIA

Tin

   Fenix Metals*    POLAND

Tin

   Gejiu Fengming Metallurgy Chemical Plant*    CHINA

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

   Guangdong Hanhe Non-Ferrous Metal Co., Ltd.*    CHINA

Tin

   HuiChang Hill Tin Industry Co., Ltd.*    CHINA

Tin

   Luna Smelter, Ltd.*    RWANDA

Tin

   Ma’anshan Weitai Tin Co., Ltd.*    CHINA

Tin

   Magnu’s 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

   Metallo Spain S.L.U.*    SPAIN

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

 

15


Mineral

  

Smelter or Refinery Facility Name

  

Country

Tin

   Operaciones Metalurgicas S.A.*    BOLIVIA

Tin

   PT Artha Cipta Langgeng*    INDONESIA

Tin

   PT ATD Makmur Mandiri Jaya*    INDONESIA

Tin

   PT Babel Surya Alam Lestari*    INDONESIA

Tin

   PT Bangka Serumpun*    INDONESIA

Tin

   PT Menara Cipta Mulia*    INDONESIA

Tin

   PT Mitra Stania Prima*    INDONESIA

Tin

   PT Prima Timah Utama*    INDONESIA

Tin

   PT Rajawali Rimba Perkasa*    INDONESIA

Tin

   PT Rajehan Ariq*    INDONESIA

Tin

   PT Refined Bangka Tin*    INDONESIA

Tin

   PT Stanindo Inti Perkasa*    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

   Thai Nguyen Mining and Metallurgy Co., Ltd.*    VIETNAM

Tin

   Thaisarco*    THAILAND

Tin

   Tin Technology & Refining*    UNITED STATES OF AMERICA

Tin

   White Solder Metalurgia e Mineracao Ltda.*    BRAZIL

Tin

   Yunnan Chengfeng Non-ferrous Metals Co., Ltd.*    CHINA

Tin

   Yunnan Tin Company Limited*    CHINA

Tin

   Yunnan Yunfan Non-ferrous Metals Co., Ltd.*    CHINA

Tungsten

   A.L.M.T. Corp.*    JAPAN

Tungsten

   Chenzhou Diamond Tungsten Products Co., Ltd.*    CHINA

Tungsten

   Chongyi Zhangyuan Tungsten Co., Ltd.*    CHINA

Tungsten

   Fujian Ganmin RareMetal 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

   Hunan Chenzhou Mining Co., Ltd.*    CHINA

Tungsten

   Hunan Chunchang Nonferrous Metals Co., Ltd.*    CHINA

Tungsten

   Hunan Litian Tungsten Industry Co., Ltd.*    CHINA

Tungsten

   Hydrometallurg, JSC*    RUSSIA

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

 

16


Mineral

  

Smelter or Refinery Facility Name

  

Country

Tungsten

   Jiangxi Yaosheng Tungsten Co., Ltd.*    CHINA

Tungsten

   JSC “Kirovgrad Hard Alloys Plant”**    RUSSIA

Tungsten

   Kennametal Huntsville*    UNITED STATES OF AMERICA

Tungsten

   KGETS Co., Ltd.*    SOUTH KOREA

Tungsten

   Lianyou Metals Co., Ltd.*    TAIWAN

Tungsten

   Malipo Haiyu Tungsten Co., Ltd.*    CHINA

Tungsten

   Masan High-Tech Materials*    VIETNAM

Tungsten

   Niagara Refining LLC*    UNITED STATES OF AMERICA

Tungsten

   Philippine Chuangxin Industrial Co., Inc.*    PHILIPPINES

Tungsten

   TANIOBIS Smelting GmbH & Co. KG*    GERMANY

Tungsten

   Wolfram Bergbau und Hutten AG*    AUSTRIA

Tungsten

   Xiamen Tungsten (H.C.) Co., Ltd.*    CHINA

Tungsten

   Xiamen Tungsten Co., Ltd.*    CHINA

Tungsten

   Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.*    CHINA

 

Smelter and refiner facility names and locations as reported by the RMI as of March 1, 2021.

*

Denotes smelters and refiners which are conformant to a responsible mineral sourcing validation program as of March 1, 2021.

**

Denotes smelters and refiners which are participating in a responsible mineral sourcing validation program as of March 1, 2021.

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 1, 2021. As of March 1, 2021, 100% of the reported smelter and refiner facilities are conformant or are participating in a responsible mineral sourcing validation program. All 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 as of March 1, 2021. 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 become conformant to 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 and 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.

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


In 2017, we began surveying Intel manufacturing suppliers to identify cobalt smelters and refiners in our microprocessor supply chain. We have since expanded this practice to include suppliers of product components in order to conduct broader risk management and to pursue responsible cobalt sourcing across a wider range of Intel products.

In 2020, Intel conducted a supply chain survey of 47 suppliers that we determined may contribute intentionally added cobalt to our products using the Cobalt Reporting Template (CRT), a supply chain survey designed by the RMI to identify the smelters and refiners that process the necessary cobalt contained in our products and the associated country of origin. Out of these 47 surveyed suppliers, 42 responded with a completed CRT, giving an 89% overall CRT completion rate. The remaining five suppliers submitted a timeline for completion that we will continue to track and drive in 2021. We will also continue to work on education and capability building with our suppliers to improve our completion rate and data accuracy. We are using the information obtained to conduct due diligence on the identified smelters and refiners and actively focus our outreach efforts to encourage RMAP involvement. Participation in a program such as RMAP verifies these facilities have management systems in place to ensure the cobalt they process is responsibly sourced in alignment with OECD Guidance. Although on-site outreach was not possible due to the COVID-19 pandemic, we conducted virtual outreach to smelters and refiners not yet participating in RMAP and worked with direct suppliers to facilitate alternative sourcing where appropriate.

As of March 1, 2021, we have identified 38 cobalt smelters and refiners reported by surveyed suppliers in our supply chain. Of those 38 smelters and refiners, 27 (71%) are either conformant or have begun participating in RMAP. Of the remaining smelters and refiners, 10 are eligible to participate in RMAP and we continue to conduct outreach to encourage participation. We identified one facility reported in our supply chain that is not eligible for RMAP participation, and we requested all six suppliers reporting this facility to use alternate sourcing for products sold to Intel. Of the six suppliers reporting this facility, five were able to report alternate sourcing by March 1, 2021. We continue to work with the remaining supplier to remove this facility from our supply chain.

Intel strongly believes that collaboration among industry, government, NGOs, 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. This is demonstrated by our previous collaboration with RMI to establish industry standards regarding responsible cobalt sourcing, including the CRT and the RMAP Cobalt Due Diligence Standard. Intel has continued its cobalt efforts by actively participating in RMI’s Cobalt Working Group, Cobalt Taskforce, and ASM Working Group, which contributed to The Cobalt Action Partnership’s development of a common set of best practices and minimum standards for cobalt that is mined on an artisanal and small-scale basis (ASM). Intel recognizes the local socio-economic importance of the ASM sector in CAHRAs and seeks to assist ASM sites in meeting downstream compliance requirements through our contributions to the Better Mining ASM Mine Monitoring Program in partnership with RMI and RCS Global. 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.

Intel RISE Responsible Minerals Sourcing Initiative

In May of 2020, we announced Intel’s corporate RISE Strategy to create a more responsible, inclusive, and sustainable world, enabled through technology and our collective actions. As a key technology industry initiative within our RISE goals, Intel committed, by 2030, to significantly broaden our impact in responsible minerals and accelerate the creation of sourcing standards for a much wider set of minerals across CAHRAs globally.

The first step in expanding our efforts to cover all minerals used in semiconductor manufacturing was to prioritize the next phase of minerals for inclusion in Intel’s responsible sourcing program. This was accomplished by compiling Intel usage data, known mineral risks, and prevalence of sourcing from CAHRAs. We compared our work with analyses and initiatives being undertaken by stakeholders in the industry, which led us to select aluminum, copper, nickel, and silver as the next phase of minerals to incorporate into our program. As an early step in this commitment, Intel has joined The Copper Mark as a Partner Member, where we can contribute to standards as well as help define and engage in due diligence within the copper and nickel supply chains. Our next steps will be working with our suppliers to map our supply chain for this next phase of minerals, as well as ensuring standards are in place that will allow Intel to pursue its ultimate goal of ensuring the minerals in our supply chain are responsibly sourced in alignment with OECD Guidance. Additionally, we will continue to identify the highest priority minerals to establish the next phase of minerals to achieve our 2030 RISE goals and objectives.

 

18


Intel’s mission for the future is to maintain the positive progress we have made on 3TG and cobalt to date, and to proactively address emerging risks from the expanding scope of materials and geographies. Our ambition is to apply our learning from the past decade and to work with our industry to broaden and accelerate the creation of sourcing standards for a much wider set of minerals globally.

 

Intel and the Intel logo, Intel Atom, Intel Core, Tofino, and Xeon 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” and “Intel RISE Responsible Minerals Sourcing Initiative” sections are not required by the Rule and are furnished as a supplement to this Report.

 

19