UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
MICROCHIP TECHNOLOGY INCORPORATED
(Exact Name of Registrant as Specified in Its Charter)
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Delaware | 0-21184 | 86-0629024 |
| (State or Other Jurisdiction of Incorporation or Organization) | (Commission File No.) | (IRS Employer Identification No.) |
2355 W. Chandler Blvd., Chandler, AZ 85224-6199
(Address of Principal Executive Offices, Including Zip Code)
J. Eric Bjornholt, Senior Vice President, Chief Financial Officer (480) 792-7200
(Name and telephone number, including area code, of the person to contact in connection with this report)
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Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies: |
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☒ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
Section 1 – Conflict Minerals Disclosures
Item 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
Microchip Technology Incorporated's ("Microchip's") Conflict Minerals Report for the reporting period January 1, 2023, through December 31, 2023, is provided as Exhibit 1.01 hereto and is publicly available at www.microchip.com/doclisting/investorshome.aspx. Microchip's product descriptions, disclosure of countries of origin, statements regarding recycled and scrap sources, and determinations and related disclosures are included in Microchip's Conflict Minerals Report and are incorporated by reference in this Section.
Section 2 – Exhibits
Item 2.01 Exhibits
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
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May 17, 2024 | Microchip Technology Incorporated
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| By: /s/ J. Eric Bjornholt |
| J. Eric Bjornholt
Senior Vice President, Chief Financial Officer
(Principal Accounting and Financial Officer) |
EXHIBIT 1.01
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| CONFLICT MINERALS REPORT |
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| MICROCHIP TECHNOLOGY INCORPORATED |
| In Accord with Rule 13p-1 Under the Securities Exchange Act of 1934 |
This report for the year ended December 31, 2023, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1"). Rule 13p-1 was adopted by the United States Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank"). Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain conflict minerals necessary to the functionality or production of their products. Conflict Minerals are defined by Rule 13p-1 as gold, cassiterite, columbite-tantalite, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten.
If a registrant has reason to believe that any conflict minerals in their supply chain may have originated in the Democratic Republic of the Congo ("DRC") or an adjoining country ("Covered Countries"), or if they are unable to determine the country of origin of conflict minerals or that their products are manufactured entirely from recycled and scrap sources, then the issuer must exercise due diligence on the source and chain of custody of the conflict minerals. The registrant must annually submit a Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures. This report is Microchip Technology Incorporated's CMR for the reporting calendar year ended December 31, 2023.
This report is not audited, as Rule 13p-1 and current SEC guidance provide that if the registrant is not declaring products as "DRC Conflict Free," the CMR is not subject to an independent private sector audit ("IPSA").
1. COMPANY OVERVIEW
MICROCHIP TECHNOLOGY INCORPORATED develops, manufactures, contracts to manufacture and sells specialized semiconductor products used by its customers in a wide variety of embedded control applications. Microchip Technology Incorporated was incorporated in Delaware in 1989. In this CMR, "we," "us," and "our" each refers to Microchip Technology Incorporated and its subsidiaries ("Microchip"). Our executive offices are located at 2355 West Chandler Boulevard, Chandler, Arizona 85224-6199 and our telephone number is (480) 792-7200.
Our Internet address is www.microchip.com. This CMR will be posted on our website with other SEC filings under About/Investor Relations as soon as reasonably practicable after it is electronically filed with the SEC. All of our SEC filings are available on our website free of charge. Additionally, this CMR will be posted on our designated Responsible Minerals Sourcing webpage at the internet address https://www.microchip.com/en-us/about/corporate-responsibility/our-supply-chain.
The information on our website is not incorporated into this CMR.
1.1 Microchip Products
Microchip is a leading provider of smart, connected and secure embedded control solutions. Its easy-to-use development tools and comprehensive product portfolio enable customers to create optimal designs, which reduce risk while lowering total system cost and time to market. The company's solutions serve approximately 125,000 customers across the automotive, aerospace and defense, communications, consumer appliances, data centers and computing, and industrial markets. Headquartered in Chandler, Arizona, Microchip offers outstanding technical support along with dependable delivery and quality.
A more detailed discussion of our product categories and the products relating to each category for calendar year 2023 are contained in our Annual Reports and SEC filings available on: https://www.microchip.com/en-us/about/investors/stock-information/sec-filings.
For the purposes of this report, Microchip’s products are further delineated in the table below separating integrated circuits from all other types of products.
All references to “Microchip” products hereafter include Microchip and all subsidiaries’ products in Categories A and B that were manufactured by Microchip or its subsidiaries, or contracted by Microchip or its subsidiaries to be manufactured, and within the scope of Rule 13p-1 ("Microchip products") unless specifically attributed to Microchip or a specific subsidiary (e.g. "Microchip Category A products" vs. "subsidiary Category A products").
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| Conflict Minerals Disclosure Category | Conflict Minerals Product Description |
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| A | Integrated circuits including touch screen controller ICs (e.g., PIC® Microcontrollers, Microprocessors, dsPIC® Digital Signal Controllers, touch and gesture sensing solutions, analog and interface, RF front-end products, wireless audio, USB and wireless solutions, embedded security products, memory products, medical electronics, LED drivers, printer/EL drivers, telecommunications, general industrial). Integrated circuits including field programmable gate arrays ("FPGAs"), Application-Specific Integrated Circuits ("ASICs"), Power-over-Ethernet ICs and legacy discrete components |
| B | RF modules and touch screen controller boards |
| System-in-Package (SiP) hybrid modules |
System on chip solutions ("SoCs"), Power management products, timing and synchronization devices and precise time solutions, voice processing devices, radio frequency ("RF") solutions, discrete components contained in peripheral equipment, enterprise storage and communication solution products, midspans, security technologies and scalable anti-tamper products, Ethernet solutions, as well as custom design capabilities and services |
| R&D application development printed circuit boards and system kits |
During the analysis of Microchip products it was found that small quantities of tin, tantalum, tungsten and/or gold ("3TG"), necessary to their functionality or production, are found in substantially all Microchip products (Categories A and B).
1.2 Conflict Minerals Report
For all product categories, Microchip has been unable to conclusively determine the origin of the 3TG that its products contain, or to conclusively determine to what extent they come from recycled or scrap sources, the facilities used to process them, their country of origin, or their mine or location of origin. Microchip’s suppliers reported at broad levels, often at the company or large product family level. None of Microchip's suppliers identified which of their suppliers sourced Microchip products, and none of our suppliers reported that all entities that they identified on their Responsible Minerals Initiative Conflict Minerals Reporting Template ("RMI-CMRT") sourced any portion of Microchip products. This report describes Microchip’s Reasonable Country of Origin Inquiry (“RCOI”) for context, the due diligence measures taken on the 3TG source and chain of custody, a description of the products manufactured or contracted to be manufactured for which Microchip controlled the design and specified or approved the utilized materials, as well as the results of its due diligence efforts, and expected risk assessment and mitigation steps.
1.3 Conflict Minerals Policy
Microchip has a conflict minerals policy. Our policy is available on our company website at https://www.microchip.com/en-us/about/corporate-responsibility/our-supply-chain.
2. MICROCHIP’S REASONABLE COUNTRY OF ORIGIN INQUIRY (RCOI) RESULTS
Since 2020, Microchip has been contracting with an industry leading third-party provider to help in conducting our annual RCOIs for our supply chains.
2.1 Category A Products
For Category A products, beginning in July 2023, Microchip sent requests with a set of instructional documents to its well-defined raw material suppliers and contract manufacturers, requesting completion of the RMI CMRT.
The responses were reviewed against developed criteria to determine valid answers and to identify candidates for subsequent inquiry ("Response Criteria"). For Microchip Category A inquiries, responses were received from all first-tier suppliers. Most responses were considered valid in first submission, while some required subsequent inquiries.
TABLE 1
Category A Products, Smelter Metrics - 2151 Total Smelters
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| Metal | Smelters recognized by the RMI RMAP to be Conformant with their responsible minerals sourcing protocols | Smelters actively participating in sourcing audits by RMI RMAP, TI-CMC, LBMA, or similar | Smelters that use 100% scrap or recycled sources | Smelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered Countries |
| Tantalum | 31 of 31 | 0 of 31 | 4 of 31 | 11 of 31 |
| Tin | 64 of 65 | 1 of 65 | 11 of 65 | 6 of 65 |
| Tungsten | 31 of 31 | 0 of 31 | 6 of 31 | 6 of 31 |
| Gold | 88 of 88 | 0 of 88 | 36 of 88 | 5 of 88 |
All smelters for Category A products known to source from the Covered Countries, or for which there is reason to believe may source from the Covered Countries, are recognized as Conformant with RMI Responsible Minerals Assurance Process (RMAP) protocols and are listed on the RMI's "Conformant" smelter list.
1 The total number of reported smelters represents verified legitimate smelters or refiners of 3TGs, that have been reported by at least one of our suppliers in our 2023 RCOI. Data is provided by our third-party due diligence consultants.
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2.2 Category B Products
As with Category A products, Microchip started the RCOI for Category B products in July 2023. Having previously identified and queried the printed circuit board manufacturers and the subcontract manufacturers’ unique materials, it successfully expanded its inquiry of discrete component manufacturers for all categories and manufacturers of peripheral equipment.
TABLE 2
Category B Products, Smelter Metrics - 3532 Total Smelters
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| Metal | Smelters recognized by the RMI RMAP to be Conformant with their responsible minerals sourcing protocols | Smelters actively participating in sourcing audits by RMI RMAP, TI-CMC, LBMA, or similar | Smelters not actively participating in sourcing audits by RMI RMAP, TI- CMC, LBMA, or similar | Smelters that use 100% scrap or recycled sources | Smelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered Countries |
| Tantalum | 33 of 35 | 0 of 35 | 2 of 35 | 4 of 35 | 13 of 35 |
| Tin | 66 of 88 | 3 of 88 | 19 of 88 | 14 of 88 | 9 of 88 |
| Tungsten | 34 of 55 | 1 of 55 | 20 of 55 | 12 of 55 | 6 of 55 |
| Gold | 90 of 175 | 3 of 175 | 82 of 175 | 56 of 175 | 17 of 175 |
Forty-five smelters for Category B products are known to source from, or there is reason to believe they may be sourcing from, the Covered Countries. Thirty-four of these smelters are recognized as Active or Conformant with RMI Responsible Minerals Assurance Process (RMAP). The remaining eleven smelters are not recognized as RMAP-Conformant, thus requiring additional due diligence. For more information on these smelters, please see section 3.3.1 titled “Category B Identified Risks.”
3. MICROCHIP'S DUE DILIGENCE PROCESS
3.1 Design of Due Diligence
Microchip made a good faith effort in the reporting year to work within the framework of the Organization for Economic Co-Operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing ("OECD Guidance") and related Supplements for 3TG, as it relates to its position in the supply chain as a “downstream company.”
2 The total number of reported smelters represents verified legitimate smelters or refiners of 3TGs that have been reported by at least one of our suppliers in our 2023 RCOI. Data is provided by our third-party due diligence consultants.
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3.2 OECD Step 1: Strong Company Management Systems
Microchip operates under a set of Guiding Values and a Code of Business Conduct & Ethics that form the foundation of all management systems at Microchip. Our Guiding Values and Code of Business Conduct & Ethics can be found on our website: https://www.microchip.com/en-us/about/corporate-responsibility/our-company. Continuing through the reporting year, Microchip expressed its concern and commitment regarding conflict minerals sourcing from the DRC and Covered Countries in a publicly available policy statement on conflict minerals as outlined in Section 1.3.
In addition, Microchip communicates our concern and commitment regarding conflict minerals sourcing from the DRC and Covered Countries in our Terms and Conditions of Purchase that accompany every order acknowledgement.
3.2.1 Internal Team
Continuing through the reporting year, Microchip's management system for conflict minerals included a team of corporate representatives from relevant functions, including ESG Assurance, legal, manufacturing, corporate environmental services, Product Material Compliance, supply management, and risk management. The team is sponsored by Microchip's Sr. VP of Backend Operations, and senior management was briefed about the results of due diligence efforts, including minerals sourcing risks.
The conflict minerals team is responsible for implementing the conflict minerals compliance strategy, including formalizing conflict minerals due diligence practices, developing supplier risk assessment criteria and responses to risk. The team is led by the Associate Director, ESG Assurance, who acts as the conflict minerals program manager.
3.2.2 Supply Chain Control Systems
To encourage the establishment of a system of controls and transparency over the mineral supply, Microchip participates in the Responsible Minerals Initiative ("RMI"). Participation allows Microchip to promote validation programs (such as the RMAP or standards enacted by the London Bullion Market Association (“LBMA”) or the Responsible Jewellery Council (“RJC”)), increase our knowledge of smelters and refiners in the supply chain, understand the scope and process for audit and validation program plans for metal-specific trade organizations, gain insight into which smelters are known to source from the covered countries, and join discussions of emerging practical due diligence experiences. During the reporting year, Microchip engaged two third-party due diligence consultants experienced with smelter sourcing research and with proven records of smelter engagement. The consultants reviewed smelter data obtained from
Microchip’s 2023 RCOI for Category A products and raw, unsorted smelter data from 2023 RCOI for Category B products, and then prepared a technical file for each. Mineral sourcing risk, including customer perception of sourcing risk, was presented to Microchip's senior management.
3.2.3 Microchip Supplier Engagement
In Calendar Year 2023, Microchip engaged an industry-leading third-party provider to help conduct our supplier engagement. This engagement included training and educational materials and supplier support. Microchip and the third-party provider reviewed responses against criteria designed to determine the number of valid responses ("Response Criteria") and followed up with corrections and clarifications as needed.
Microchip’s supplier engagement activities in the reporting year focused primarily on Category A suppliers. During the reporting year, Microchip requested completion of the RMI CMRT by raw material suppliers and subcontract manufacturers of Category A products and ultimately received a 100% response rate from those said suppliers.
For Microchip’s Category B products, Microchip continued its engagement with the second and third-tier discrete component and peripheral equipment suppliers using the RMI CMRT and educational materials, but continued to encounter circumstances where some manufacturers of the discrete components declined to provide a completed CMRT due to the indirect nature of Microchip’s relationship with such suppliers (Microchip’s contract manufacturers are discrete component suppliers’ direct customers and are therefore not responsible for sharing details regarding the discrete components). Microchip has begun to work more closely with its contract manufacturers to bridge this gap, however, hurdles still exist with the discrete component suppliers. During the reporting year, Microchip received a >75% response rate from suppliers for Category B products.
3.2.4 Grievance Mechanism
Microchip provides grievance mechanisms so that employees, suppliers, and others can report suspected non-compliance with legal requirements and suspected non-compliance with Microchip's Code of Business Conduct & Ethics.
Our Code of Business Conduct & Ethics policy (HR-690), Compliance with Laws policy (HR-685) and Reporting Legal Non-Compliance policy (HR-675) include complaint procedures. These policies are publicly available at https://www.microchip.com/en-us/about/corporate-responsibility/our-company.
For conflict minerals related grievances, Microchip employees and external parties may also submit concerns or information to ConflictMinerals@Microchip.com.
3.2.5 Maintain Records
Microchip has developed a process for collecting and retaining RCOI and due diligence documentation that was directed, controlled, and archived by the conflict minerals team.
3.3 OECD Step 2: Identification and Assessment of Risk in the Supply Chain
Because of Microchip’s size, the complexity of its products, and the depth, breadth, and evolution of its supply chain, it may be challenging to identify suppliers upstream from its first tier (direct) suppliers. Accordingly, Microchip identifies direct suppliers which may contain conflict minerals and pursues smelter identification using the RMI CMRT. Additionally, Microchip leverages its membership in the RMI as an integral part of its supply chain identification and due diligence and risk assessment process. Furthermore, Microchip uses its third-party due diligence consultants to gain insight into Smelters' or Refiners' (SORs') sourcing practices, and their internal due diligence procedures to help with risk assessment.
3.3.1 Category B Identified Risks
The following smelters pose a potential risk due to sourcing (or we have reason to believe they may be sourcing) from the Covered Countries and not being RMAP-Conformant:
African Gold Refinery (CID003185, Gold)
Augmont Enterprises Private Limited (CID003461, Gold)
Dijllah Gold Refinery FZC (CID003348, Gold)
Emirates Gold DMCC (CID002561, Gold)
Fidelity Printers and Refiners Ltd. (CID002515, Gold)
Fujairah Gold FZC (CID002584, Gold)
Industrial Refining Company (CID002587, Gold)
International Precious Metal Refiners (CID002562, Gold)
Sam Precious Metals (CID003666, Gold)
Shirpur Gold Refinery Ltd. (CID002588, Gold)
Sudan Gold Refining (CID002567, Gold)
When it is discovered that a smelter or refiner presents a credible risk of irresponsible sourcing based upon our third-party due diligence research, Microchip will work with and educate its suppliers about the risks of
having this type of smelter in its supply chain and, where necessary, begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable.
3.4 OECD Step 3: Strategy to Respond to Identified Risks
Microchip believes that understanding smelter sourcing practices is the best method that can eventually lead to the determination of a product's conflict status. To that end, Microchip is a member of the RMI and it reviews the lists of smelters reported by its supply chain against the RMI’s RMAP "Conformant" smelter lists, the "Active" smelter lists, and the TI-CMC "Active" smelter list (TI-CMC Category A, Members Progressing Toward RMAP Validation). In addition, Microchip utilizes RMI-recognized third-party consultants to help identify risks throughout its supply chain. It also engages with those suppliers who are believed to be supplying 3TG from sources that support conflict in the Covered Countries, with an end goal of establishing an acceptable alternative source of 3TG not supporting such conflict. Microchip also engages with smelters reported by its supply chain and for which we can locate viable contact information to voluntarily participate in the RMI RMAP or similar sourcing audit programs leading to recognition by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols.
3.5 OECD Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
Microchip does not typically have a direct relationship with 3TG smelters and refiners and does not perform direct audits of these entities within its supply chain. Microchip does, however, leverage its third-party due diligence consultants to contact smelters and refiners with which it does not have direct relationships or which it does not have the ability to contact. Using its third-party due diligence consultants, Microchip gains insight into SORs’ sourcing practices and their internal due diligence procedures. Microchip’s third-party due diligence consultants also encourage non-conformant/non-participating SORs to become conformant by joining the RMI or affiliated groups on Microchip’s behalf. Additionally, Microchip utilizes and supports the due diligence conducted by programs like the RMI to conduct and coordinate third-party audits to validate 3TG processor sourcing practices.
3.6 OECD Step 5: Report Annual Supply Chain Due Diligence
Microchip’s Due Diligence Review criteria includes a determination of the geographic location, whether there is a known, actively mined, and economically viable reserve of 3TG in the area, whether there is positive evidence of responsible and/or irresponsible sourcing, whether there is contrary evidence of responsible sourcing - all from publicly available sources, the smelters’ websites, the UN Group of Experts, NGOs, the RMI and similar organizations,
and from our due diligence consultant’s communication with certain smelters. Please refer to Section 3.3 of this Conflict Minerals Report for the discussion on the steps taken on these eleven findings.
As a result of continuous due diligence with suppliers and smelters through its third-party consultant teams, Microchip has determined that approximately 99.5% of smelters in its Category A product supply chain are RMAP conformant and 0.5% are actively pursuing their conformant status as of the end of our RCOI.
Similarly, as a result of our continuous due diligence with suppliers and smelters which are part of Microchip’s Category B product supply chain as well as through working with third-party consultants, Microchip has determined that approximately 63% of its smelters are RMAP conformant, 2% are actively pursuing their conformant status, and 35% are currently not enrolled in a validation program. This is an increase from last year and may be due to reliance on 3rd party databases for this information as we do not have a direct relationship with many of these suppliers. In many instances further outreach is not possible.
Based on RCOI information provided by suppliers in Microchip's supply chains, its due diligence efforts, and due diligence provided by our third-party consultants, the SORs that may have processed the 3TG in Microchip's Category A products include those listed in Table 1. The SORs that may have processed the 3TG in Category B products include those listed in Table 2.
Based on its due diligence efforts, Microchip does not have sufficient information to conclusively determine the countries of origin for the 3TG in its products. Based on the information provided by Microchip's suppliers, our third-party due diligence consultants, the RMI, and others, Microchip believes that the countries of origin for the 3TG in our products include the countries listed in Table 7 and Table 8.
While fifty-seven smelters in Category A products were identified as exclusively using scrap or recycled sources of 3TG, it was determined that no correlation can be made to any specific Microchip Category A product type, technology family, or part number. No Microchip Category A product is made exclusively with 3TG solely sourced from scrap or recycled sources.
Additionally, although eighty-six smelters in Category B products were found to source from scrap or recycled sources of 3TG exclusively, it was determined that no correlation can be made to any specific Microchip Category B product types, technology family, or part number. No Category B product is made exclusively with 3TG solely sourced from scrap or recycled sources.
Microchip's independent due diligence produced information suggesting twenty-eight reported smelters in Category A products either are known to source from the Covered Countries, or there is reason to believe they may or could
source from the Covered Countries based upon business relationships. Each of these smelters is recognized by the RMI to be Conformant with the organization’s responsible minerals sourcing protocols and are listed on the RMI RMAP “Conformant” smelter lists.
In Category B products, Microchip's independent due diligence produced information suggesting forty-five reported smelters either as known to source from the Covered Countries or there is reason to believe they may source from the Covered Countries. Thirty-two of the smelters are recognized by the RMI to be “Conformant” with the organization’s responsible minerals sourcing protocols and are listed on the RMI RMAP “Conformant” smelter lists. For the thirteen smelters reported to be in the supply chain for Category B products that were not recognized by the RMI as Conformant, Microchip performed additional due diligence.
In addition to this CMR, Microchip communicates its conflict minerals activities in its annual Sustainability Report and in the conflict minerals sourcing policy, which are available on our company website: https://www.microchip.com/en-us/about/corporate-responsibility. The information on our website is not incorporated into this CMR.
3.6.2 Efforts to Determine Mine or Location of Origin
Microchip has established that participation in RMI, requesting its suppliers complete the RMI CMRT, and retaining third-party due diligence consultants in the reporting year are reasonable ways to determine the mines or countries of origin of the 3TG in its supply chain. Microchip’s Countries of Origin and Reason to Believe Countries of Origin list as provided by the best of its ability based on data provided by the third-party due diligence consultants is listed in Table 7 and Table 8 of this CMR.
3.6.3 Smelters or Refiners
Microchip does not source 3TG directly from the Covered Countries, and Microchip typically does not source 3TG directly from smelters or refiners. The exceptions are gold sputter targets, gold bond wire, and tin anode. All gold sputter targets, gold bond wire, and tin anode, were purchased from smelters or refiners recognized by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols.
Based on RCOI information provided by suppliers in Microchip’s supply chains, its own due diligence efforts, and due diligence provided by its consultants, the facilities that may have processed the 3TG in Microchip’s Category A products include those listed in Table 1.
4. STEPS TO BE TAKEN TO MITIGATE RISK
Microchip intends to take the following steps to improve the due diligence and further mitigate risk of using necessary 3TGs which could potentially benefit armed groups in the Covered Countries:
a.Continue to work with the RMI and/or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance and/or other SEC recognized framework.
b.Consolidate RCOI and due diligence practices and activities into a conflict minerals management system. Continue to retain third-party due diligence consultants experienced with smelter sourcing research and direct smelter engagement.
c.Conduct bi-annual reporting year RCOI for Category A products using the RMI CMRT. Microchip will communicate its expectation that suppliers for Category A products continue working to remove uncooperative smelters and smelters that are not actively participating with the RMI RMAP, or similar sourcing programs, from the products they provide to Microchip.
d.Conduct annual reporting year RCOI for Category B products using RMI CMRT. Microchip will communicate its expectation that suppliers for Category B products continue working to remove uncooperative smelters and smelters that are not actively participating with the RMI RMAP, or similar sourcing programs, from the products they provide to Microchip through Microchip's contract manufacturers.
e.Continue to develop supplier engagement strategies that may improve the RCOI response rate for Category B suppliers where Microchip is a second-tier customer or lower.
f.Through our efforts or those of our due diligence consultants, engage with selected smelters to encourage participation with the RMI RMAP responsible minerals sourcing audits.
g.Continue to remove smelters from our Category A supply chain that become uncooperative with the RMI RMAP or who were, at one time, voluntarily participating with the RMI RMAP responsible minerals sourcing audit program or similar programs, but who have fallen off the “Conformant” smelter lists (unless the RMI places the smelter into its “smelters undergoing extended corrective action” category). Microchip will review the business need for a smelter in this category and may, depending on the cause for removal and the nature and content of affirmative commitments made by the affected smelter, choose to retain the smelter in its supply chain.
h.Engage with direct suppliers found to be supplying us with 3TG from sources that support conflict in any Covered Country to seek to establish an acceptable alternative source of 3TG.
TABLE 5
Category A Products
Smelters Reported to be in Supply Chain
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| Metal | Smelter Name | Smelter Country |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | Agosi AG | GERMANY |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| 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 Ronnskar | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Dowa | JAPAN |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| 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 | Gold by Gold Colombia | COLOMBIA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | 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 | 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Materion | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| 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 | MKS PAMP SA | SWITZERLAND |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF |
| Gold | Nihon Material Co., Ltd. | JAPAN |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| 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 | SAFINA A.S. | CZECHIA |
| 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 |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| 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 | KOREA, REPUBLIC OF |
| 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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 | AMG Brasil | BRAZIL |
| Tantalum | D Block Metals, LLC | 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 | 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 | Materion Newton Inc. | UNITED STATES OF AMERICA |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| 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 | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| 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 | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tin | Alpha | UNITED STATES OF AMERICA |
| Tin | Aurubis Beerse | BELGIUM |
| Tin | Aurubis Berango | SPAIN |
| 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 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| Tin | CRM Synergies | SPAIN |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tin | Dowa | JAPAN |
| Tin | DS Myanmar | MYANMAR |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Estanho de Rondonia S.A. | BRAZIL |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA |
| Tin | Luna Smelter, Ltd. | RWANDA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE |
| 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 (PLURINATIONAL STATE OF) |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Bangka Serumpun | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | PT Premium Tin Indonesia | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | PT Rajehan Ariq | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Sukses Inti Makmur (SIM) | INDONESIA |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Super Ligas | BRAZIL |
| Tin | Thaisarco | THAILAND |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| 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 |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CHINA |
| 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 Fallon | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| 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 |
TABLE 6
Category B Products
Smelters Reported to be in Supply Chain
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | 8853 S.p.A. | ITALY |
| Gold | ABC Refinery Pty Ltd. | AUSTRALIA |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA |
| Gold | African Gold Refinery | UGANDA |
| Gold | Agosi AG | GERMANY |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES |
| Gold | Albino Mountinho Lda. | PORTUGAL |
| Gold | Alexy Metals | UNITED STATES OF AMERICA |
| 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 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY |
| Gold | AU Traders and Refiners | SOUTH AFRICA |
| Gold | Augmont Enterprises Private Limited | INDIA |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangalore Refinery | INDIA |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden Ronnskar | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | Caridad | MEXICO |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | CGR Metalloys Pvt Ltd. | INDIA |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Chugai Mining | JAPAN |
| Gold | Coimpa Industrial LTDA | BRAZIL |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY |
| Gold | Dijllah Gold Refinery FZC | UNITED ARAB EMIRATES |
| Gold | Dongwu Gold Group | CHINA |
| Gold | Dowa | JAPAN |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| 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 | Emerald Jewel Industry India Limited (Unit 1) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | INDIA |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE |
| Gold | Fujairah Gold FZC | UNITED ARAB EMIRATES |
| Gold | GG Refinery Ltd. | TANZANIA, UNITED REPUBLIC OF |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | INDIA |
| Gold | Gold by Gold Colombia | COLOMBIA |
| Gold | Gold Coast Refinery | GHANA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA |
| Gold | Guangdong Jinding Gold Limited | CHINA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Heraeus Germany GmbH Co. KG | GERMANY |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF |
| Gold | Industrial Refining Company | BELGIUM |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
| Gold | International Precious Metal Refiners | UNITED ARAB EMIRATES |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Italpreziosi | ITALY |
| Gold | JALAN & Company | INDIA |
| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CHINA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | K.A. Rasmussen | NORWAY |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN |
| 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Kundan Care Products Ltd. | INDIA |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA |
| Gold | Lingbao Gold Co., Ltd. | CHINA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA |
| Gold | L'Orfebre S.A. | ANDORRA |
| Gold | LS MnM Inc. | KOREA, REPUBLIC OF |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA |
| Gold | Marsam Metals | BRAZIL |
| Gold | Materion | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | MD Overseas | INDIA |
| Gold | Metal Concentrators SA (Pty) Ltd. | SOUTH AFRICA |
| Gold | Metallix Refining Inc. | UNITED STATES OF AMERICA |
| 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 | MKS PAMP SA | SWITZERLAND |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Modeltech Sdn Bhd | MALAYSIA |
| Gold | Morris and Watson | NEW ZEALAND |
| 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 | NH Recytech Company | KOREA, REPUBLIC OF |
| 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 | Pease & Curren | UNITED STATES OF AMERICA |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA |
| Gold | Planta Recuperadora de Metales SpA | CHILE |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Precinox S.A. | SWITZERLAND |
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA |
| Gold | REMONDIS PMR B.V. | NETHERLANDS |
| Gold | Royal Canadian Mint | CANADA |
| Gold | SAAMP | FRANCE |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA |
| Gold | Safimet S.p.A | ITALY |
| Gold | SAFINA A.S. | CZECHIA |
| Gold | Sai Refinery | INDIA |
| Gold | Sam Precious Metals | UNITED ARAB EMIRATES |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA |
| Gold | Shandong Humon Smelting Co., Ltd. | CHINA |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CHINA |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | CHINA |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CHINA |
| Gold | Shirpur Gold Refinery Ltd. | INDIA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA |
| Gold | Sovereign Metals | INDIA |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA |
| Gold | Sudan Gold Refinery | SUDAN |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Super Dragon Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Gold | T.C.A S.p.A | ITALY |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN |
| Gold | Torecom | KOREA, REPUBLIC OF |
| 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 | WEEEREFINING | FRANCE |
| 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 |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Tantalum | 5D Production OU | ESTONIA |
| Tantalum | AMG Brasil | BRAZIL |
| Tantalum | D Block Metals, LLC | 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 Rising Rare Metals-EO Materials Ltd. | CHINA |
| 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 | Materion Newton Inc. | UNITED STATES OF AMERICA |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA |
| Tantalum | Mineracao Taboca S.A. | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | NPM Silmet AS | ESTONIA |
| Tantalum | PowerX Ltd. | RWANDA |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
| 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 | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA |
| Tin | Alpha | UNITED STATES OF AMERICA |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIETNAM |
| Tin | Aurubis Beerse | BELGIUM |
| Tin | Aurubis Berango | SPAIN |
| 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 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | BRAZIL |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tin | CRM Synergies | SPAIN |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CHINA |
| Tin | Dowa | JAPAN |
| Tin | DS Myanmar | MYANMAR |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIETNAM |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Estanho de Rondonia S.A. | BRAZIL |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | BRAZIL |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | 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 | Jiangxi New Nanshan Technology 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 | Malaysia Smelting Corporation Berhad (Port Klang) | MALAYSIA |
| Tin | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA |
| Tin | Mineracao Taboca S.A. | BRAZIL |
| Tin | Mining Minerals Resources SARL | CONGO, DEMOCRATIC REPUBLIC OF THE |
| Tin | Minsur | PERU |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Modeltech Sdn Bhd | MALAYSIA |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | Novosibirsk Tin Combine | RUSSIAN FEDERATION |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Pongpipat Company Limited | MYANMAR |
| Tin | Precious Minerals and Smelting Limited | INDIA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | INDONESIA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Bangka Serumpun | INDONESIA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | PT Cipta Persada Mulia | INDONESIA |
| Tin | PT Menara Cipta Mulia | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Mitra Sukses Globalindo | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Premium Tin Indonesia | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Putera Sarana Shakti (PT PSS) | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa | INDONESIA |
| Tin | PT Rajehan Ariq | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Sukses Inti Makmur (SIM) | INDONESIA |
| Tin | PT Timah Nusantara | INDONESIA |
| Tin | PT Timah Tbk Kundur | INDONESIA |
| Tin | PT Timah Tbk Mentok | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tirus Putra Mandiri | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA |
| Tin | Super Ligas | BRAZIL |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | JAPAN |
| Tin | Thaisarco | THAILAND |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CHINA |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIETNAM |
| Tin | VQB Mineral and Trading Group JSC | VIETNAM |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | A.L.M.T. Corp. | JAPAN |
| Tungsten | ACL Metais Eireli | BRAZIL |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| Tungsten | Artek LLC | RUSSIAN FEDERATION |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CHINA |
| Tungsten | Cronimet Brasil Ltda | BRAZIL |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | KOREA, REPUBLIC OF |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Global Tungsten & Powders LLC | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
| Tungsten | HANNAE FOR T Co., Ltd. | KOREA, REPUBLIC OF |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CHINA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CHINA |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | 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 Minmetals Gao'an Non-ferrous Metals 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 | JSC "Kirovgrad Hard Alloys Plant" | RUSSIAN FEDERATION |
| Tungsten | Kenee Mining Corporation Vietnam | VIETNAM |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA |
| Tungsten | Lianyou Metals Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Lianyou Resources Co., Ltd. | TAIWAN, PROVINCE OF CHINA |
| Tungsten | LLC Vostok | RUSSIAN FEDERATION |
| Tungsten | MALAMET SMELTING SDN. BHD. | MALAYSIA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
| Tungsten | Masan High-Tech Materials | VIETNAM |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION |
| Tungsten | Nam Viet Cromit Joint Stock Company | VIETNAM |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA |
| Tungsten | NPP Tyazhmetprom LLC | RUSSIAN FEDERATION |
| Tungsten | OOO “Technolom” 1 | RUSSIAN FEDERATION |
| Tungsten | OOO “Technolom” 2 | RUSSIAN FEDERATION |
| Tungsten | Philippine Carreytech Metal Corp. | PHILIPPINES |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | CHINA |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY |
| Tungsten | Tungsten Vietnam Joint Stock Company | VIETNAM |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| | | | | | | | |
| Metal | Smelter Name | Smelter Country |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CHINA |
TABLE 7
Category A Countries of Origin4
| | | | | | | | | | | |
| ANDORRA | CZECHIA | MYANMAR | TAIWAN, PROVINCE OF CHINA |
| AUSTRALIA | ESTONIA | NETHERLANDS | THAILAND |
| AUSTRIA | GERMANY | PERU | TURKEY |
| BELGIUM | INDIA | PHILIPPINES | UNITED STATES OF AMERICA |
| BOLIVIA (PLURINATIONAL STATE OF) | INDONESIA | POLAND | UZBEKISTAN |
| BRAZIL | ITALY | RWANDA | VIETNAM |
| CANADA | JAPAN | SINGAPORE | |
| CHILE | KAZAKHSTAN | SOUTH AFRICA | |
| CHINA | KOREA, REPUBLIC OF | SPAIN | |
| COLOMBIA | MALAYSIA | SWEDEN | |
| CONGO, DEMOCRATIC REPUBLIC OF THE | MEXICO | SWITZERLAND | |
4 Microchip’s Countries of Origin and Reason to Believe Countries of Origin list as provided by the best of our ability based on data provided by our third-party due diligence consultants.
27
TABLE 8
Category B Countries of Origin5
| | | | | | | | | | | | | | |
| ANDORRA | CZECHIA | KYRGYZSTAN | PORTUGAL | TANZANIA, UNITED REPUBLIC OF |
| AUSTRALIA | ESTONIA | LITHUANIA | RUSSIAN FEDERATION | THAILAND |
| AUSTRIA | FRANCE | MALAYSIA | RWANDA | TURKEY |
| BELGIUM | GERMANY | MEXICO | SAUDI ARABIA | UGANDA |
| BOLIVIA (PLURINATIONAL STATE OF) | GHANA | MYANMAR | SINGAPORE | UNITED ARAB EMIRATES |
| BRAZIL | INDIA | NETHERLANDS | SOUTH AFRICA | UNITED STATES OF AMERICA |
| CANADA | INDONESIA | NEW ZEALAND | SPAIN | UZBEKISTAN |
| CHILE | ITALY | NORWAY | SUDAN | VIETNAM |
| CHINA | JAPAN | PERU | SWEDEN | ZIMBABWE |
| COLOMBIA | KAZAKHSTAN | PHILIPPINES | SWITZERLAND | |
| CONGO, DEMOCRATIC REPUBLIC OF THE | KOREA, REPUBLIC OF | POLAND | TAIWAN, PROVINCE OF CHINA | |
5 Microchip’s Countries of Origin and Reason to Believe Countries of Origin list as provided by the best of our ability based on data provided by our third-party due diligence consultants.
28
Caution Concerning Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Such forward-looking statements include the statements that we are working toward an end goal to establish an acceptable alternative source of 3TG not supporting conflict, that we plan to engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that support conflict in the DRC, that certain smelters pose a potential risk due to sourcing (or we have reason to believe they may be sourcing from the Covered Countries and not being RMAP-Conformant), that Microchip will work with and educate its suppliers about the risks of having this type of smelter in its supply chain and, where necessary, begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable, and the steps set forth in Section 4 that we intend to take to improve the due diligence conducted. We also use words such as "anticipate," "believe," "plan," "expect," "future," "intend" and similar expressions to identify forward-looking statements. All forward-looking statements involve risk and uncertainty. Our actual results could differ materially from the results anticipated in these forward-looking statements for a number of reasons including changes in our supply chain, our ability or inability to obtain an adequate supply of materials from current or alternative suppliers and the cost of such materials, the level of cooperation we receive from our suppliers with respect to our further due diligence, changes in regulations in the U.S. or other countries (including the Covered Countries), or changes in political or economic conditions in the U.S. or other countries (including the Covered Countries). For a detailed discussion of these and other risk factors, please refer to Microchip's filings on forms 10-K and 10-Q. You can obtain copies of Forms 10-K and 10-Q and other relevant documents for free at Microchip's website (www.microchip.com) or the SEC's website (www.sec.gov) or from commercial document retrieval services. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. Although we believe that the expectations reflected in the forward-looking statements are reasonable, we cannot guarantee future results, levels of activity, performance or achievements. You should not place undue reliance on these forward-looking statements. We disclaim any obligation to update information contained in any forward-looking statement.
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