UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549



Form SD



Specialized Disclosure Report

NATIONAL INSTRUMENTS CORPORATION

(Exact name of the registrant as specified in its charter)

Delaware
000-25426
(State or other jurisdiction of incorporation or organization)
(Commission File Number)

11500 North MoPac Expressway
 
78759
Austin, Texas
(Address of principal executive offices)
 
(Zip Code)

R. Eddie Dixon, Jr.
 
(512) 683-0100
(Name and telephone number, including area code, of person to contact in connection with this report)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.

Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the reporting period from January 1 to December 31, 2021.



Section 1 – Conflict Minerals Disclosure

Item 1.01
Conflict Minerals Disclosure and Report

GENERAL

National Instruments Corporation (the “Company,” “NI,” “we,” “us” or “our”) started over 40 years ago on an idea of connecting engineers through software. Our founders created technology to connect instruments to computers in order to accelerate the testing and measurement of innovative technology, and this was the seed of a philosophy of accelerating innovation that continues to be a driving force of our culture, our business, and our operations today. We strive to enable customers around the world to do their most ambitious work while meeting fast-moving market demands. We provide the integration of modular hardware and open, flexible software systems, to consistently support organizations’ evolving test and measurement needs. NI is headquartered in Austin, Texas, was incorporated under the laws of the State of Texas in May 1976 and was reincorporated in Delaware in June 1994. In March 1995, we completed an initial public offering of our common stock. Our common stock, $0.01 par value, is quoted on the NASDAQ Stock Market under the trading symbol NATI.

In 2010 the US Congress enacted the conflict minerals provisions of the Dodd-Frank Financial Reform legislation. The law’s aim is to curb violence and human rights abuses in the Democratic Republic of the Congo (DRC), the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola by requiring disclosure of certain information by public companies that use certain minerals which are necessary to the functionality or production of their products, which minerals include gold, columbite-tantalite (coltan), cassiterite and wolfamite, including their derivatives which are limited to tantalum, tin and tungsten (collectively, the “Conflict Minerals”).

COVERED PRODUCTS

Most NI hardware products and systems contain at least one of the Conflict Minerals and fall into the scope of the law’s requirements; thus, this disclosure includes information on a company-level basis that includes general information for our hardware products. We offer two primary hardware form factors, PXI and NI C-series, both with a modular input/output (“I/O”) approach in addition to industry standard PCI form factors. The NI PXI modular instrument platform, introduced in 1997, is a standard PC architecture in a rugged form factor with expansion slots and instrumentation extensions for timing, triggering, and signal sharing. PXI combines mainstream PC software and PCI hardware with advanced instrumentation capabilities. The NI C-series platform, used in our CompactRIO and CompactDAQ products, is a rugged, high-performance I/O and processing platform used in a wide variety of data acquisition applications. The NI PXI and C-series platforms include field programmable gate array (“FPGA”) technology, giving customers programmable hardware capability that provides high performance and is user-customizable with NI LabVIEW software. One example of our application-specific systems is our NI Semiconductor Test System (“STS”) which combines NI modular instrumentation with NI software for RF and mixed-signal production testing. The STS features fully production-ready test systems that use NI technology in a form factor suitable for a semiconductor production test environment. The STS combines the NI PXI hardware, TestStand test management software, and LabVIEW graphical programming software inside a fully enclosed test head. The compact STS design houses all the key components of a production tester while using a fraction of the floor space, power, and maintenance typically required by traditional automated test equipment.

Reasonable Country of Origin Inquiry Description

For calendar year 2021, NI has conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the conflict minerals necessary to the functionality or production of NI Products originated in the DRC or an adjoining country or came from scrap or recycled sources.


The Company’s RCOI process included reviewing the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release and conducting an inquiry of our direct suppliers of the in-scope products using the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Based on the results of our RCOI which indicated sourcing from the DRC or an adjoining country, we exercised due diligence on the source and chain of custody of the conflict minerals in accordance with the OECD Due Diligence Guidance.

Conflict Minerals Disclosure

This Form SD of NI is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2021 to December 31, 2021.


A copy of NI’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD and is publicly available at http://investor.ni.com/. This website and the information contained therein or connected thereto are not intended to be incorporated into this Form SD or the Conflict Minerals Report.

Item 1.02
Exhibit

As specified in Section 2, Item 2.01 of this Form SD, NI is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this report.

Section 2 – Resource Extraction Issuer Disclosure

Item 2.01
Resource Extraction Issuer Disclosure and Report

Not applicable.

Section 3 – Exhibits

Item 3.01
Exhibits

The following exhibit is filed as part of this report.

Exhibit 1.01
Conflict Minerals Report of National Instruments Corporation for the reporting period from January 1 to December 31, 2021.


SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

   
NATIONAL INSTRUMENTS CORPORATION
 
       
 
By:
/s/ R. Eddie Dixon, Jr.
 
   
R. Eddie Dixon, Jr.
 
   
Chief Legal Officer, Senior Vice President & Secretary
 

Date:  May 31, 2022




Exhibit 1.01
CONFLICT MINERALS REPORT OF
NATIONAL INSTRUMENTS CORPORATION
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2021



I.          Introduction
 
This is the Conflict Minerals1 Report of National Instruments Corporation (“we,” “our,” “us,” “NI,” or the “Company”) prepared for calendar year 2021 in accordance with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”), as amended. Numerous terms in this Report are defined in Rule 13p-1 of the Act and SEC Release No. 34-67716 (August 22, 2012) under the Act (the “Adopting Release”). The reader is referred to these sources for the definitions of defined terms contained herein.
 
In accordance with Rule 13p-1, we undertook efforts to determine the presence and source of the conflict minerals within our products. The Company designed its efforts in conformity with the internationally recognized due diligence framework set forth in the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas2 (“OECD Due Diligence Guidance”) and related Supplements.
 
The statements below are based on the activities performed to date in good faith by the Company and are based on the infrastructure and information available at the time of this filing. Factors that could affect the accuracy of these statements include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, gaps in supplier or smelter education and knowledge, supplier and smelter unfamiliarity with the protocol, evolving identification of smelters, incomplete information from industry or other third-party sources, all instances of Conflict Minerals necessary to the functionality or manufacturing of NI’s products possibly not yet having been identified, timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, oversights or errors in conformant smelter audits, Covered Countries sourced materials being declared secondary materials, companies going out of business in 2021, certification programs being not equally advanced for all industry segments and metals, smuggling of Conflict Minerals from the Covered Countries to countries beyond the covered countries, continuing guidance regarding the SEC final rules, and other issues.
 
II.         Overview
 
Company Profile
 
National Instruments Corporation started over 40 years ago on an idea of connecting engineers through software. Our founders created technology to connect instruments to computers in order to accelerate the testing and measurement of innovative technology, and this was the seed of a philosophy of accelerating innovation that continues to be a driving force of our culture, our business, and our operations today. We strive to enable customers around the world to do their most ambitious work while meeting fast-moving market demands. We provide the integration of modular hardware and open, flexible software systems, to consistently support organizations’ evolving test and measurement needs. NI is headquartered in Austin, Texas, was incorporated under the laws of the State of Texas in May 1976 and was reincorporated in Delaware in June 1994. In March 1995, we completed an initial public offering of our common stock. Our common stock, $0.01 par value, is quoted on the NASDAQ Stock Market under the trading symbol NATI.


1 The term “conflict mineral” is defined in Section 1502(e)(4) of the Dodd-Frank Wall Street Reform and Consumer Protection Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo (“DRC”) or an adjoining country.

2 OECD (2016), OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing, Paris.


We are subject to this rule as we have determined that, during 2021, conflict minerals were likely necessary to the functionality or production of products we manufactured or contracted to manufacture. The Company, as a purchaser of component parts, is many steps removed from the mining of conflict minerals. We do not purchase raw ore or unrefined conflict minerals and we conduct no purchasing activities directly in the DRC or adjoining countries.
 
Conflict Minerals Policy
 
The Company developed a policy statement to support the goals expressed by Congress in enacting Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The policy highlights the Company’s commitment to complying with the reporting and due diligence obligations required by the SEC rule and our expectations from our suppliers. The policy as well as our supplier code of conduct and terms and conditions include language highlighting our expectation for suppliers to source responsibly. The policy resides on our corporate website (http://ni.com/conflictminerals).
 
Reasonable Country of Origin Inquiry Information
 
We have conducted a good faith reasonable country of origin inquiry (“RCOI”) to determine whether the necessary conflict minerals originated in the DRC or an adjoining country or came from recycled or scrap sources.
 
The Company’s RCOI process included reviewing the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release and conducting an inquiry of our direct suppliers of the in-scope products using the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Based on the results of our RCOI which indicated sourcing from the DRC or an adjoining country, we exercised due diligence on the source and chain of custody of the conflict minerals in accordance with the OECD Due Diligence Guidance. Our due diligence efforts are discussed further in this Conflict Minerals Report.
 
Due Diligence Program Design
 
The Company designed its conflict minerals program to conform, in all material respects, with the five-step framework of the OECD Due Diligence Guidance, the Supplement on Tin, Tantalum, and Tungsten, and the Supplement on Gold, specifically as they relate to our position in the minerals supply chain as a “downstream” company:
 
Step 1:   Establish strong company management systems
Step 2:   Identify and assess risks in the supply chain
Step 3:   Design and implement a strategy to respond to identified risks
Step 4:   Carry out independent third-party audit of smelter/refiner’s due diligence practices
Step 5:   Report annually on supply chain due diligence
 
III.        Due Diligence Measures Performed by The Company
 
The following describes the measures taken to reasonably determine the country of origin and to exercise due diligence in the mineral supply chain in conformance with the OECD Due Diligence Guidance.
 
Step 1: Establish strong company management systems
 
a.
Conflict minerals team – The Company established a conflict minerals team that includes individuals from the relevant business units and departments, including trade compliance, procurement, sales, and legal. The team was structured to include the involvement from those in upper management roles, including the Senior VP of Manufacturing, Director of Trade Compliance, and Global Supply Chain Operations Manager, to help ensure that critical information, including the Company’s conflict minerals policy, reached relevant employees and suppliers.
b.
Conflict minerals policy – The Company adopted and published a policy establishing the expectations of our suppliers. The policy resides on our corporate website (http://ni.com/conflictminerals). The Company’s expectation for the responsible sourcing of minerals is also incorporated into the Company’s terms and conditions with suppliers.


c.
Supplier engagement – The Company communicated its conflict minerals policy and provided educational materials to our in-scope suppliers. Suppliers were informed when the request for information was initiated on the conflict minerals disclosure requirements as well as recommendations for developing, implementing, and documenting a conflict minerals compliance program. NI also communicated its conflict minerals position statement to its suppliers through the NI Supplier Code of Conduct, available online at ni.com/en-us/about-ni/suppliers.html, which is designed to inform potential and existing suppliers about the Company. Finally, NI requires that its suppliers abide by the NI Supplier Code of Conduct and the labor, health and safety, environmental, and ethics standards of the most current version of the Responsible Business Alliance (RBA) Code of Conduct.
d.
Company-level grievance mechanism – As recommended by the OECD Due Diligence Guidance, the Company has a grievance mechanism in place as a risk-awareness system for conflict minerals issues. NI maintains an ethics hotline pursuant to which stakeholders, internal and external, may confidentially report concerns involving conflict minerals, either electronically or by phone.
e.
Records management – The Company will maintain records relating to our conflict minerals program in accordance with the recommended record retention guidelines of five years.
 
Step 2: Identify and assess risks in the supply chain
 
We performed the following steps as part of our risk assessment process:
 
a.
Identified products in scope – Our conflict minerals team conducted a detailed review of the products manufactured or contracted to be manufactured during the Reporting Period to identify products that should be deemed in-scope as described by the Adopting Release. As most NI hardware products contain at least one of the Conflict Minerals this disclosure includes information on a company-level basis that includes general information for all NI products.
b.
Conducted RCOI – The Company utilized the most recent version of the industry-developed CMRT to query our suppliers for conflict minerals information. We requested this information from the Tier 1 suppliers who provide materials and components for NI products. We evaluated the responses from the templates submitted by our suppliers to determine our reporting obligation based on this RCOI. See Appendix I for a list of countries of origin identified through the RCOI process.
c.
Completed additional follow-up – The Company contacted direct suppliers multiple times to request detailed conflict minerals information. We also worked to clarify and validate the accuracy of information provided by our suppliers by responding with standardized feedback questions to address any issues or uncertainty with the template provided when necessary and/or obtaining additional information upon request (product identification, order numbers, or shipping addresses) to help ensure we are receiving conflict minerals information specific to our supply-chain.
d.
Identified smelters or refiners (“SORs”) – The Company compiled a list of SORs in our supply chain using our suppliers’ responses in their CMRTs. The Company reconciled this list to the list of smelter facilities designated by the RMI’s Responsible Minerals Assurance Process (“RMAP”). The RMAP completes independent, third-party audits of smelters and refiners to determine which can be validated as having systems in place that help ensure the minerals are responsible sourced according to the OECD Due Diligence Guidance. The company also utilized information provided by the London Bullion Market Association (“LBMA”), and Responsible Jewelry Council (“RJC”) cross-recognition audit programs. The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs. We have provided that list in this report within section IV – Product Description; Processing Facilities.
 
Step 3: Design and implement a strategy to respond to identified risks
 
We performed the following steps as part of our risk management plan:
 
a.
Reporting results to senior management – The Conflict Minerals team reports the results of our RCOI to upper management at multiple points in time throughout the data collection period. These communications included the team’s plan to respond to risks identified in the due diligence processes.
b.
Designed and implemented a plan – The Company used established risk rating criteria to evaluate suppliers based on the responses provided within their CMRT, as well as, any additional documentation furnished to support those responses and the suppliers’ due diligence processes. The resulting risk ratings were used to develop specific supplier outreach to address the identified risks and to take corrective actions with suppliers found not in compliance with the Company’s conflict minerals policy. These actions will include additional outreach to suppliers who failed to respond to our multiple requests for information,  provided inconsistent or erroneous information, or indicated they had received responses from less than 50% of their in-scope suppliers. Our team further reviews the responses to verify the validity of SORs reported by our suppliers, the audit status of such SORs and the country of origin of the minerals processed at such facilities.


c.
Provided educational materials – The Company provided each supplier with educational materials that explain Section 1502 of the Dodd Frank Act, the OECD framework, the RCOI process, and general information on the contents of the most recent revision of the CMRT (including definitions of common phrases and frequently asked questions). The educational material serves as a point of reference for suppliers that are unfamiliar with the rule and helps limit the risk of obtaining inaccurate information from them.
d.
Identified SORs – As part of the risk mitigation process, the Company reconciled the list of SORs collected from suppliers to the list of smelter facilities validated by the RMI.  The Company maintains a database of smelter aliases to reconcile suppliers’ smelters lists to the list of RMI SORs.
 
Step 4: Carry out independent third-party audit of smelter/refiner’s due diligence practices
 
The Company is using information provided by independent third-party audit programs, including the RMI, RMAP, LBMA, and RJC, to confirm the existence and verify the OECD-conformance status of SORs identified during our due diligence.
 
For SORs that had not been audited as conformant, the Company sent a communication to encourage participation in the RMAP and requested the SOR to provide the mines and/or locations the SOR sources from to assist in identifying all countries of origin. Additionally, the Company sent communications to all suppliers that reported SORs that had not been audited as conformant to request that these suppliers contact the SORs to encourage participation in the RMAP.
 
The Company is also a member of the RMI {Member Code: NAIN}. As a member, the Company financially supports the development of the RMAP and utilizes the RMI data to determine the country of origin of conflict minerals in the Company’s products in addition to the Company’s efforts of reaching out to smelters. The efforts to determine location of origin through the RMI are described in the RMI’s Reasonable Country of Origin Inquiry Data methodology available on its website.
 
Step 5: Report annually on supply chain due diligence
 
Accordingly, this Conflict Minerals Report has been filed with the SEC and is available on our website at http://investor.ni.com/.
 

IV.        Product Description; Processing Facilities

Product Description  Most NI hardware products and systems contain at least one of the Conflict Minerals and fall into the scope of the law’s requirements; thus, the following description includes information on a company-level basis that includes general information for our hardware products. We offer two primary hardware form factors, PXI and NI C-series, both with a modular input/output (“I/O”) approach in addition to industry standard PCI form factors. The NI PXI modular instrument platform, introduced in 1997, is a standard PC architecture in a rugged form factor with expansion slots and instrumentation extensions for timing, triggering and signal sharing. PXI combines mainstream PC software and PCI hardware with advanced instrumentation capabilities. The NI C-series platform, used in our CompactRIO and CompactDAQ products, is a rugged, high-performance I/O and processing platform used in a wide variety of data acquisition applications. The NI PXI and C-series platforms include field programmable gate array (“FPGA”) technology, giving customers programmable hardware capability that provides high performance and is user-customizable with NI LabVIEW software. One example of our application-specific systems is our NI Semiconductor Test System (“STS”) which combines NI modular instrumentation with NI software for RF and mixed-signal production testing. The STS features fully production-ready test systems that use NI technology in a form factor suitable for a semiconductor production test environment. The STS combines the NI PXI hardware, TestStand test management software, and LabVIEW graphical programming software inside a fully enclosed test head. The compact STS design houses all the key components of a production tester while using a fraction of the floor space, power, and maintenance typically required by traditional automated test equipment.
 
Processing FacilitiesBased on our due diligence process and the information received from our suppliers, the following facilities were identified by the Company’s suppliers as the smelters and refiners of the tin, tantalum, tungsten and/or gold present in and necessary to the functionality of products manufactured by the Company in the calendar year ended December 31, 2021. The information from our suppliers is still evolving and may contain company-level declarations. As such, this smelter list is presented in good faith as the best information we have to date. For 2021 we identified 137 SORs in our supply chain, and 130 have been audited as conformant with the RMAP. This list may contain smelters that are not in our supply chain and/or there may be other smelters not yet identified in our due diligence process. We will continue to update the list as our information and the relevant third-party data from RMI, LBMA, and RJC improves.
 
 


 
Metal
 
Standard_Smelter_Name
 
Country_Location
 
Entity_ID
 
Gold
 
Advanced Chemical Company
 
UNITED STATES OF AMERICA
 
CID000015
 
Gold
 
Agosi AG
 
GERMANY
 
CID000035
 
Gold
 
Western Australian Mint (T/a The Perth Mint)
 
AUSTRALIA
 
CID002030
 
Gold
 
Aida Chemical Industries Co., Ltd.
 
JAPAN
 
CID000019
 
Gold
 
Dowa
 
JAPAN
 
CID000401
 
Gold
 
Almalyk Mining and Metallurgical Complex (AMMC)
 
UZBEKISTAN
 
CID000041
 
Gold
 
Asahi Pretec Corp.
 
JAPAN
 
CID000082
 
Gold
 
AngloGold Ashanti Corrego do Sitio Mineracao
 
BRAZIL
 
CID000058
 
Gold
 
Argor-Heraeus S.A.
 
SWITZERLAND
 
CID000077
 
Gold
 
Asahi Refining Canada Ltd.
 
CANADA
 
CID000924
 
Gold
 
Asahi Refining USA Inc.
 
UNITED STATES OF AMERICA
 
CID000920
 
Gold
 
Asaka Riken Co., Ltd.
 
JAPAN
 
CID000090
 
Gold
 
Aurubis AG
 
GERMANY
 
CID000113
 
Gold
 
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
 
PHILIPPINES
 
CID000128
 
Gold
 
Boliden AB
 
SWEDEN
 
CID000157
 
Gold
 
C. Hafner GmbH + Co. KG
 
GERMANY
 
CID000176
 
Gold
 
CCR Refinery - Glencore Canada Corporation
 
CANADA
 
CID000185
 
Gold
 
Chimet S.p.A.
 
ITALY
 
CID000233
 
Gold
 
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
 
CHINA
 
CID002224
 
Gold
 
Shandong Gold Smelting Co., Ltd.
 
CHINA
 
CID001916
 
Gold
 
DSC (Do Sung Corporation)
 
KOREA, REPUBLIC OF
 
CID000359
 
Gold
 
Eco-System Recycling Co., Ltd. East Plant
 
JAPAN
 
CID000425
 
Gold
 
Emirates Gold DMCC
 
UNITED ARAB EMIRATES
 
CID002561
 
Gold
 
Moscow Special Alloys Processing Plant
 
RUSSIAN FEDERATION
 
CID001204
 
Gold
 
JSC Novosibirsk Refinery
 
RUSSIAN FEDERATION
 
CID000493
 
Gold
 
Heimerle + Meule GmbH
 
GERMANY
 
CID000694
 
Gold
 
Heraeus Metals Hong Kong Ltd.
 
CHINA
 
CID000707
 
Gold
 
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
 
CHINA
 
CID000801
 
Gold
 
Ishifuku Metal Industry Co., Ltd.
 
JAPAN
 
CID000807
 
Gold
 
Istanbul Gold Refinery
 
TURKEY
 
CID000814
 
Gold
 
Japan Mint
 
JAPAN
 
CID000823
 
Gold
 
Jiangxi Copper Co., Ltd.
 
CHINA
 
CID000855
 
Gold
 
JSC Uralelectromed
 
RUSSIAN FEDERATION
 
CID000929
 
Gold
 
JX Nippon Mining & Metals Co., Ltd.
 
JAPAN
 
CID000937
 
Gold
 
Kazzinc
 
KAZAKHSTAN
 
CID000957
 
Gold
 
Kennecott Utah Copper LLC
 
UNITED STATES OF AMERICA
 
CID000969
 
Gold
 
Kojima Chemicals Co., Ltd.
 
JAPAN
 
CID000981
 
Gold
 
Korea Zinc Co., Ltd.
 
KOREA, REPUBLIC OF
 
CID002605
 
Gold
 
LS-NIKKO Copper Inc.
 
KOREA, REPUBLIC OF
 
CID001078
 
Gold
 
Materion
 
UNITED STATES OF AMERICA
 
CID001113
 
Gold
 
Matsuda Sangyo Co., Ltd.
 
JAPAN
 
CID001119
 
Gold
 
Sumitomo Metal Mining Co., Ltd.
 
JAPAN
 
CID001798
 
Gold
 
Metalurgica Met-Mex Penoles S.A. De C.V.
 
MEXICO
 
CID001161
 
Gold
 
Umicore S.A. Business Unit Precious Metals Refining
 
BELGIUM
 
CID001980
 
Gold
 
Metalor Technologies S.A.
 
SWITZERLAND
 
CID001153
 
Gold
 
Metalor Technologies (Hong Kong) Ltd.
 
CHINA
 
CID001149
 
Gold
 
Metalor Technologies (Singapore) Pte., Ltd.
 
SINGAPORE
 
CID001152
 
Gold
 
Metalor Technologies (Suzhou) Ltd.
 
CHINA
 
CID001147
 
Gold
 
Metalor USA Refining Corporation
 
UNITED STATES OF AMERICA
 
CID001157
 
Gold
 
Mitsubishi Materials Corporation
 
JAPAN
 
CID001188
 
Gold
 
Mitsui Mining and Smelting Co., Ltd.
 
JAPAN
 
CID001193
 
Gold
 
MMTC-PAMP India Pvt., Ltd.
 
INDIA
 
CID002509
 
Gold
 
Nadir Metal Rafineri San. Ve Tic. A.S.
 
TURKEY
 
CID001220


 
Gold
 
Nihon Material Co., Ltd.
 
JAPAN
 
CID001259
 
Gold
 
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
 
AUSTRIA
 
CID002779
 
Gold
 
Ohura Precious Metal Industry Co., Ltd.
 
JAPAN
 
CID001325
 
Gold
 
OJSC “The Gulidov Krasnoyarsk Non-Ferrous
Metals Plant” (OJSC Krastsvetmet)
 
RUSSIAN FEDERATION
 
CID001326
 
Gold
 
PAMP S.A.
 
SWITZERLAND
 
CID001352
 
Gold
 
Prioksky Plant of Non-Ferrous Metals
 
RUSSIAN FEDERATION
 
CID001386
 
Gold
 
PT Aneka Tambang (Persero) Tbk
 
INDONESIA
 
CID001397
 
Gold
 
PX Precinox S.A.
 
SWITZERLAND
 
CID001498
 
Gold
 
Rand Refinery (Pty) Ltd.
 
SOUTH AFRICA
 
CID001512
 
Gold
 
Royal Canadian Mint
 
CANADA
 
CID001534
 
Gold
 
SEMPSA Joyeria Plateria S.A.
 
SPAIN
 
CID001585
 
Gold
 
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
 
CHINA
 
CID001622
 
Gold
 
Tanaka Kikinzoku Kogyo K.K.
 
JAPAN
 
CID001875
 
Gold
 
Singway Technology Co., Ltd.
 
TAIWAN, PROVINCE OF CHINA
 
CID002516
 
Gold
 
Solar Applied Materials Technology Corp.
 
TAIWAN, PROVINCE OF CHINA
 
CID001761
 
Gold
 
T.C.A S.p.A
 
ITALY
 
CID002580
 
Gold
 
Tokuriki Honten Co., Ltd.
 
JAPAN
 
CID001938
 
Gold
 
Torecom
 
KOREA, REPUBLIC OF
 
CID001955
 
Gold
 
Umicore Precious Metals Thailand
 
THAILAND
 
CID002314
 
Gold
 
United Precious Metal Refining, Inc.
 
UNITED STATES OF AMERICA
 
CID001993
 
Gold
 
Valcambi S.A.
 
SWITZERLAND
 
CID002003
 
Gold
 
WIELAND Edelmetalle GmbH
 
GERMANY
 
CID002778
 
Gold
 
Yamakin Co., Ltd.
 
JAPAN
 
CID002100
 
Gold
 
Yokohama Metal Co., Ltd.
 
JAPAN
 
CID002129
 
Tantalum
 
Changsha South Tantalum Niobium Co., Ltd.
 
CHINA
 
CID000211
 
Tantalum
 
D Block Metals, LLC
 
UNITED STATES OF AMERICA
 
CID002504
 
Tantalum
 
F&X Electro-Materials Ltd.
 
CHINA
 
CID000460
 
Tantalum
 
FIR Metals & Resource Ltd.
 
CHINA
 
CID002505
 
Tantalum
 
Global Advanced Metals Aizu
 
JAPAN
 
CID002558
 
Tantalum
 
Global Advanced Metals Boyertown
 
UNITED STATES OF AMERICA
 
CID002557
 
Tantalum
 
XIMEI RESOURCES (GUANGDONG) LIMITED
 
CHINA
 
CID000616
 
Tantalum
 
TANIOBIS Co., Ltd.
 
THAILAND
 
CID002544
 
Tantalum
 
H.C. Starck Hermsdorf GmbH
 
GERMANY
 
CID002547
 
Tantalum
 
H.C. Starck Inc.
 
UNITED STATES OF AMERICA
 
CID002548
 
Tantalum
 
TANIOBIS Japan Co., Ltd.
 
JAPAN
 
CID002549
 
Tantalum
 
TANIOBIS Smelting GmbH & Co. KG
 
GERMANY
 
CID002550
 
Tantalum
 
TANIOBIS GmbH
 
GERMANY
 
CID002545
 
Tantalum
 
Hengyang King Xing Lifeng New Materials Co., Ltd.
 
CHINA
 
CID002492
 
Tantalum
 
Jiangxi Tuohong New Raw Material
 
CHINA
 
CID002842
 
Tantalum
 
JiuJiang JinXin Nonferrous Metals Co., Ltd.
 
CHINA
 
CID000914
 
Tantalum
 
Jiujiang Tanbre Co., Ltd.
 
CHINA
 
CID000917
 
Tantalum
 
Metallurgical Products India Pvt., Ltd.
 
INDIA
 
CID001163
 
Tantalum
 
Ningxia Orient Tantalum Industry Co., Ltd.
 
CHINA
 
CID001277
 
Tantalum
 
Yanling Jincheng Tantalum & Niobium Co., Ltd.
 
CHINA
 
CID001522
 
Tantalum
 
Ulba Metallurgical Plant JSC
 
KAZAKHSTAN
 
CID001969
 
Tin
 
Alpha
 
UNITED STATES OF AMERICA
 
CID000292
 
Tin
 
PT Refined Bangka Tin
 
INDONESIA
 
CID001460
 
Tin
 
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
 
CHINA
 
CID002158
 
Tin
 
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
 
CHINA
 
CID000228
 
Tin
 
China Tin Group Co., Ltd.
 
CHINA
 
CID001070
 
Tin
 
Tin Smelting Branch of Yunnan Tin Co., Ltd.
 
CHINA
 
CID002180
 
Tin
 
Dowa
 
JAPAN
 
CID000402


 
Tin
 
EM Vinto
 
BOLIVIA (PLURINATIONAL STATE OF)
 
CID000438
 
Tin
 
Fenix Metals
 
POLAND
 
CID000468
 
Tin
 
Minsur
 
PERU
 
CID001182
 
Tin
 
Gejiu Kai Meng Industry and Trade LLC
 
CHINA
 
CID000942
 
Tin
 
Gejiu Non-Ferrous Metal Processing Co., Ltd.
 
CHINA
 
CID000538
 
Tin
 
Malaysia Smelting Corporation (MSC)
 
MALAYSIA
 
CID001105
 
Tin
 
Mitsubishi Materials Corporation
 
JAPAN
 
CID001191
 
Tin
 
PT Timah Tbk Mentok
 
INDONESIA
 
CID001482
 
Tin
 
PT Timah Tbk Kundur
 
INDONESIA
 
CID001477
 
Tin
 
Magnu’s Minerais Metais e Ligas Ltda.
 
BRAZIL
 
CID002468
 
Tin
 
Melt Metais e Ligas S.A.
 
BRAZIL
 
CID002500
 
Tin
 
Metallic Resources, Inc.
 
UNITED STATES OF AMERICA
 
CID001142
 
Tin
 
Metallo Belgium N.V.
 
BELGIUM
 
CID002773
 
Tin
 
Mineracao Taboca S.A.
 
BRAZIL
 
CID001173
 
Tin
 
O.M. Manufacturing (Thailand) Co., Ltd.
 
THAILAND
 
CID001314
 
Tin
 
O.M. Manufacturing Philippines, Inc.
 
PHILIPPINES
 
CID002517
 
Tin
 
Operaciones Metalurgicas S.A.
 
BOLIVIA (PLURINATIONAL STATE OF)
 
CID001337
 
Tin
 
PT Mitra Stania Prima
 
INDONESIA
 
CID001453
 
Tin
 
Resind Industria e Comercio Ltda.
 
BRAZIL
 
CID002706
 
Tin
 
Rui Da Hung
 
TAIWAN, PROVINCE OF CHINA
 
CID001539
 
Tin
 
Soft Metais Ltda.
 
BRAZIL
 
CID001758
 
Tin
 
Thaisarco
 
THAILAND
 
CID001898
 
Tin
 
White Solder Metalurgia e Mineracao Ltda.
 
BRAZIL
 
CID002036
 
Tungsten
 
Chenzhou Diamond Tungsten Products Co., Ltd.
 
CHINA
 
CID002513
 
Tungsten
 
Chongyi Zhangyuan Tungsten Co., Ltd.
 
CHINA
 
CID000258
 
Tungsten
 
Ganzhou Huaxing Tungsten Products Co., Ltd.
 
CHINA
 
CID000875
 
Tungsten
 
Ganzhou Seadragon W & Mo Co., Ltd.
 
CHINA
 
CID002494
 
Tungsten
 
Global Tungsten & Powders Corp.
 
UNITED STATES OF AMERICA
 
CID000568
 
Tungsten
 
Hunan Chunchang Nonferrous Metals Co., Ltd.
 
CHINA
 
CID000769
 
Tungsten
 
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
 
CHINA
 
CID002551
 
Tungsten
 
Xiamen Tungsten (H.C.) Co., Ltd.
 
CHINA
 
CID002320
 
Tungsten
 
Xiamen Tungsten Co., Ltd.
 
CHINA
 
CID002082


V.          Future Due Diligence
 
We will continue to communicate our expectations and information requirements to our direct suppliers. Over time, we anticipate that the amount of information available globally on the traceability and sourcing of these ores will increase and improve our knowledge. We will continue to make inquiries to our direct suppliers and undertake additional risk assessments when potentially relevant changes in facts or circumstances are identified. If we become aware of a supplier whose due diligence needs improvement, we may continue the trade relationship while that supplier improves its compliance program. We expect our suppliers to take similar measures with their suppliers to ensure alignment throughout the supply chain.
 
In addition to those above, the Company will undertake the following steps during the next compliance period:

Review the conflict minerals policy statement and update if necessary.
Review supplier and employee training materials and update if necessary.
Continue to collect responses from suppliers using the most recent revision of the CMRT.
Engage with suppliers that did not provide a response in 2021 or provided incomplete responses to enhance our data collection for 2022.
Monitor and track performance of risk mitigation efforts including the performance of suppliers deemed high-risk.
Continue engagement with smelters by sending letters to those that have not been audited as conformant.
Continue to send messages to our suppliers to engage with smelters that have not been audited as conformant.
Collect from suppliers product-level or user-defined level responses where useful.
Compare and validate RCOI results to information collected via independent third-party audit programs, such as the RMI, and through our Company’s own coordinated outreach to smelters.
Encourage responsible sourcing from the DRC and adjoining countries.

Websites referenced in this Conflict Minerals Report, and the information contained in them or connected to them, are not intended to be incorporated into this Conflict Minerals Report or our Form SD.

This Conflict Minerals Report contains forward-looking statements within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, that are subject to risks and uncertainties. Any statements contained herein regarding our future financial performance, operations, due diligence, or other activities (including, without limitation, statements to the effect that we “will,” “expect,” “anticipate,” “continue,” or other variations thereof or comparable terminology or the negative thereof) should be considered forward-looking statements. All forward-looking statements are based on current expectations and projections of future events. We claim the protection of the safe harbor for forward-looking statements contained in the Private Securities Litigation Reform Act of 1995 for all forward-looking statements.  Although we believe that the expectations reflected in the forward-looking statements are reasonable, forward-looking statements are not guarantees of performance and actual results could differ materially from those projected in the forward-looking statements as a result of a number of important factors, including those set forth in the risk factors in our Form 10-K filed with the Securities and Exchange Commission (“SEC”) on February 22, 2022, our Form 10-Q filed with the SEC on April 29, 2022, and other documents filed with the SEC.  Actual results could differ materially from those stated or implied by our forward-looking statements, due to risks and uncertainties associated with our business or underlying assumptions or conditions. You should not place undue reliance on any of these forward-looking statements. Any forward-looking statement speaks only as of the date on which it is made. We disclaim any obligation to update information contained in any forward-looking statement, whether as a result of new information, future events or otherwise.


APPENDIX I – Countries of Origin

The potential country of origin information provided in this Appendix is based on the information collected from the Company’s suppliers. It is important to note that this is based, in part, on company-level responses and therefore, it is not certain that these countries of origin can be linked to our products.

Argentina
Mexico
Australia
Mongolia
Austria
Mozambique
Belgium
Myanmar
Benin
Namibia
Bolivia (Plurinational State of)
Niger
Brazil
Nigeria
Burundi*
Peru
Canada
Philippines
China
Portugal
Colombia
Russian Federation
Congo, Democratic Republic of the*
Rwanda*
Ecuador
Sierra Leone
Eritrea
South Africa
Ethiopia
South Korea
France
Spain
Germany
Swaziland
Ghana
Sweden
Guinea
Taiwan
Guyana
Tanzania*
India
Thailand
Indonesia
Uganda*
Japan
United Kingdom of Great Britain and Northern Ireland
Kazakhstan
United States of America
Kyrgyzstan
Uzbekistan
Laos
Vietnam
Madagascar
Zimbabwe
Malaysia
 

* DRC or adjoining countries