UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM SD

 

 

Specialized Disclosure Report

 

 

TERADATA CORPORATION

(Exact name of registrant as specified in its charter)

 

 

 

Delaware   001-33458   75-3236470
(State or other jurisdiction of   (Commission   (I.R.S. Employer
incorporation or organization)   File Number)   Identification No.)

17095 Via Del Campo

San Diego, California 92127

(Address of principal executive offices) (Zip Code)

Mark A. Culhane (866) 548-8348

(Name and telephone number, including area code, of the person to contact in connection with this report)

Securities registered pursuant to Section 12(b) of the Act:

 

Title of each class:

 

Trading

Symbol

 

Name of Each Exchange

on which Registered:

Common Stock, $0.01 par value   TDC   New York Stock Exchange

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, 2019.

 

 

 


Section 1 – Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

A copy of the Teradata Corporation Conflict Minerals Report for the year ended December 31, 2019 is provided as Exhibit 1.01 to this Form SD and is publicly available at www.teradata.com/corporate-social-responsibility by clicking on “Related Links” and then selecting “Teradata Conflict Minerals Report for 2019.”

Section 2—Exhibits

Item 2.01 Exhibits

 

Exhibit 1.01    Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

 

2


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 thereunto duly authorized.

 

TERADATA CORPORATION    
By:   /s/ Mark A. Culhane     Date: May 29, 2020
  Mark A. Culhane    
  Chief Financial Officer    

 

3

EX-1.01

Exhibit 1.01

Teradata Corporation

Conflict Minerals Report

For the Year Ended December 31, 2019

This Conflict Minerals Report (this “Report”) has been prepared by Teradata Corporation (“Teradata,” “we,” “us” and “our”) for the reporting period January 1 to December 31, 2019, and is presented to comply with the final Conflict Minerals implementing rules (the “Conflict Minerals Rules”) promulgated by the Securities and Exchange Commission (“SEC”) and codified in Section 13(p) of the Securities Exchange Act of 1934, as modified by SEC guidance issued on April 29, 2014 and the SEC order issued on May 2, 2014 (the “Conflict Minerals Rules”). “Conflict Minerals” are currently defined by the SEC as cassiterite, columbite-tantalite (coltan), wolframite, gold, or their derivatives, which the SEC has currently limited to tin, tantalum and tungsten (collectively, the “Subject Minerals,” “Conflict Minerals” or “3TG”).

To comply with the Conflict Minerals Rules, we conducted due diligence on the origin, source and chain of custody of the Conflict Minerals that were necessary to the functionality or production of the products that we manufactured or contracted to manufacture, for which manufacturing was completed during 2019 in order to ascertain whether these Conflict Minerals originated in the Democratic Republic of Congo or an adjoining country and financed or benefited Armed Groups (as defined in Section 1, Item 1.01(d)(2) of Form SD) in any of these countries. Our due diligence undertakings are described in this Report, which includes the activities of all our affiliates that are required to be consolidated.

When this Report uses the term “conflict-free” it means the applicable Conflict Minerals, smelters or refiners have been verified as complying with the Responsible Minerals Initiative’s (“RMI”) (formerly the Conflict-Free Sourcing Initiative) Responsible Minerals Assurance Process (“RMAP”) (formerly the Conflict-Free Smelter Program) or an equivalent third-party audit program. When this Report uses the terms the “Covered Countries,” “DRC” or “DRC Region” it means the Democratic Republic of the Congo and adjoining countries, including Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia.

 

  1.

Company Overview

Teradata is a leading hybrid cloud analytics software provider enabling customers to integrate and simplify their analytics ecosystem, access and manage data, and use analytics to extract answers and derive business value from data. Our solutions are composed of software, hardware and related business consulting and support services. Our workload-specific platforms for on-premises use include the Teradata hardware products that are within the scope of this Report. Our workload-specific platforms are used in multiple industries, including communications, ecommerce, financial services, gaming, government, healthcare, insurance, manufacturing, media and entertainment, oil and gas, retail, travel and transportation, and utilities. As of December 31, 2019, we operated 101 facilities in 41 countries and employed 8,535 people worldwide.

 

  2.

Products Overview

The equipment (excluding software) comprising our products typically includes electronic computer processors, boards, servers, data storage, power supplies, cabinetry and related tangible components. Collectively, the tangible components of those products are referred to in this Report as Teradata “hardware” or Teradata “hardware products.” Other products, including third-party equipment, that Teradata does not manufacture or contract to manufacture are outside the scope of this Report.

We engineer, design and establish specifications for our hardware products, leveraging best-in-class components from industry leaders and using industry-standard technologies selected and configured to work optimally with other hardware components and software. Each of our hardware products shares some common hardware components and/or suppliers with our other hardware products. During 2019, Teradata did not manufacture any of our hardware products. All Teradata hardware manufactured during 2019 (as well as during the years 2013-2018) for distribution to others was manufactured for us under contract by our sole-source electronics manufacturing services provider, Flex Ltd. (“Flex” or our “Contract-Manufacturer”).

 

1


We have determined that certain of these hardware products for which manufacturing was completed during 2019 contain Conflict Minerals. Those products are:

 

   

Teradata Workload-Specific Platforms, including the Teradata Active Enterprise Data Warehouse, Teradata Data Warehouse Appliance, Teradata Data Mart Appliance, Teradata Appliance for SAS® and Teradata Integrated Big Data Platform;

 

   

Teradata Aster Discovery Platforms, including the Teradata Aster Analytics Appliance;

 

   

Teradata Appliance for Hadoop;

 

   

Teradata Platform Framework Cabinet;

 

   

Teradata IntelliFlex;

 

   

Teradata IntelliBase; and

 

   

Teradata Cabinet.

 

  3.

Supply Chain Overview

During 2019, 90 suppliers, including our Contract-Manufacturer and its affiliates, directly provided hardware components and materials for Teradata hardware products (“key suppliers”). Our Contract-Manufacturer assembled those hardware components, performed and completed the manufacturing of our hardware products, and initiated distribution of those products from the United States. The hardware components and materials included in our hardware products include components and materials from multiple upstream suppliers, supplier-tiers and sources across the world. Teradata is multiple supplier-tiers downstream from the smelters and refiners that provide materials used in the supply chain for Teradata hardware components. Teradata has had no direct relationships with those smelters or refiners, and has had no direct presence, direct business activities or employees located in the Covered Countries.

 

  4.

Conflict Minerals Analysis

Based upon a review of our product categories, we have concluded that:

 

   

Teradata is subject to the Conflict Minerals Rule;

 

   

the Subject Minerals are commonly known to be used widely in the electronics industry and found in many electronic computing hardware components;

 

   

the Subject Minerals are in various Teradata hardware product components;

 

   

the Subject Minerals included in our hardware products did not originate exclusively from recycled or scrap resources; and

 

   

all of the Subject Minerals included in our hardware products did not originate exclusively from supplies that entered the supply chain before the period covered by the Rule (before January 2013).

We determined that our sole-source Contract-Manufacturer has:

 

   

declared it has a Conflict Minerals Policy available for its suppliers and publishes documents regarding such (see the Flex “Responsible Sourcing Policy” by visiting – https://flex.com/-/media/Project/Flex/BrandSite/other-pdf/supplier-information/supplier-quality/
Responsible_Sourcing_Policy_2018.pdf?revision=58874505-529c-4b5a-890a-4ca2e3cb91d1).

 

   

declared that it is a member of the RMI and that it uses the RMI Conflict Minerals Reporting Template (“CMRT”) in connection with its Conflict Minerals program (see webpages above as well as http://www.conflictfreesourcing.org/about/members-and-collaborations listing members of the RMI (which includes Flex and Teradata) and http://www.conflictfreesourcing.org which provides information about the RMI, RMAP and CMRT); and

 

2


   

identified itself as being a reporting company under the Rule and posted such a report in 2019 for products it manufactured during 2018 (see https://www.sec.gov/Archives/edgar/data/866374/000110465919030076/0001104659-19-030076-index.htm); 2018 for products it manufactured during 2017 (see https://www.sec.gov/Archives/edgar/data/866374/000110465918037147/0001104659-18-037147-index.htm); 2017 for products it manufactured during 2016 (see https://www.sec.gov/Archives/edgar/data/866374/000110465917034301/a17-13957_1sd.htm), in 2016 for products it manufactured during 2015 (see https://www.sec.gov/Archives/edgar/data/866374/000110465916123371/0001104659-16-123371-index.htm), in 2015 for products it manufactured during 2014 (see https://www.sec.gov/Archives/edgar/data/866374/000110465915042045/0001104659-15-042045-index.htm), and in 2014 for products it manufactured during 2013 (see https://www.sec.gov/Archives/edgar/data/866374/000110465914042967/a14-13522_1sd.htm).

 

  5.

Teradata’s Due Diligence Framework

Teradata has designed our Conflict Minerals Policy and associated due diligence processes to support and align with the RMI and RMAP frameworks and thereby with the five-step framework set forth in the Third Edition of the Organisation for Economic Co-operation and Development’s (“OECD”) “Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas” and the supplements thereto (see http://www.oecd.org/corporate/mne/mining.htm). The activities, websites, links and documents summarized and cited there and throughout this report address these undertakings.

 

  A.

Establishment of Robust Company Ethics and Compliance Management Systems

 

   

Teradata has adopted and maintains a Conflict Minerals Policy (the “Policy”), which can be viewed on our website at: www.teradata.com/corporate-social-responsibility. The Policy has been communicated to relevant personnel and is available to all Teradata employees via Teradata’s website. Among other things, the Policy:

 

     

authorizes and assigns responsibilities for a Teradata Conflict Minerals Management Committee;

 

     

encourages respect and protection of human rights and the environment with our supply chain;

 

     

fosters supply chain integrity, ethics, compliance and accountability, including with respect to Conflict Minerals, Conflict Minerals legal duties and Conflict Minerals industry/framework initiatives;

 

     

prohibits knowing inclusion of Targeted DRC Conflict Minerals in our hardware products;

 

     

establishes an escalation and corrective actions process in the event of actual or suspected Conflict Minerals compliance risks, exceptions or violations;

 

     

establishes an expectation or requirement with our supply chain that the 3TG content in our hardware products must become conflict-free as and when required by law and SEC guidance;

 

3


     

adopted procedures and expectations that our Conflict Minerals initiatives and status are reviewed with Teradata senior management and the Audit Committee of our Board of Directors; and

 

     

adopted procedures and expectations that our Conflict Minerals Policy is reviewed and updated at least annually and on an intermediate as-required basis to assure that any new legal developments are accounted for on a timely basis.

 

   

Teradata has prepared this Conflict Minerals Report for 2019 (replacing previously posted versions for the years 2013-2018) and posted it on our website at www.teradata.com/corporate-social-responsibility).

 

   

Teradata has declared our support for and adopted the principles of the Responsible Business Alliance, (“RBA”) formerly the Electronic Industry Citizenship Coalition (“EICC”) Code of Conduct. The RBA Code of Conduct includes provisions regarding responsible sourcing of minerals, including with respect to 3TG and DRC Region Conflict Minerals at section D.7. of the RBA Code of Conduct (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility; and, see the RBA Code of Conduct at http://www.responsiblebusiness.org/standards/code-of-conduct/.

 

   

Teradata has declared our support for and adopted the principles of the United Nations (“UN”) Global Compact (Principle Two of the UN Global Compact includes that businesses should make sure they are not complicit in human rights abuses), been a signatory to the UN Global Compact, been a financial supporter of the UN Global Compact, submitted UN Global Compact Communications on Progress (the “Teradata Corporate Social Responsibility Report”) and posted related information on our website (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility, including related information in the “Teradata Code of Conduct” and “Teradata Corporate Social Responsibility Report”; and, see information regarding the UN Global Compact, its principles, its members (including Teradata), its financial supporters (including Teradata) and its members who have submitted Communications on Progress at https://www.unglobalcompact.org/ and https://www.unglobalcompact.org/what-is-gc/participants/15948-Teradata-Corporation).

 

   

Teradata has adopted a company Code of Conduct and posted it for public access on our website, which includes provisions related to respecting and protecting human rights, our adoption of the principles of the RBA Code of Conduct and UN Global Compact and compliance regarding, among other areas, Conflict Minerals (see www.teradata.com/code-of-conduct).

 

   

We have adopted a Teradata Supplier Code of Conduct and Teradata Business Partner Code of Conduct (each includes Conflict Minerals compliance provisions and the principles of the RBA Code of Conduct and UN Global Compact) and posted them for public access on our website (see http://assets.teradata.com/pdf/Teradata_Supplier_Code_of_Conduct.pdf and http://assets.teradata.com/pdf/Teradata_Business_Partner_Code_of_Conduct.pdf).

 

   

Teradata has maintained and communicated information about the Teradata Ethics Helpline (e.g., a whistleblower hotline) though which anyone may report Teradata-related actual or suspected violations of policies or laws or raise Teradata-related issues for review and guidance, and may do so on an anonymous and confidential basis (anyone may report and seek guidance regarding Teradata-related matters that pertain to Conflict Minerals through our Ethics Helpline (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility, as well as the online site for the Teradata Ethics Helpline at https://tdhelp.alertline.com/gcs/welcome).

 

4


   

Teradata has maintained an Ethics and Compliance program and process for investigating, taking corrective actions and reporting matters related to ethics, compliance, actual or suspected violations of policies and actual or suspected violations of law (these include matters involving policies or laws that pertain to Conflict Minerals, of which there have been none) (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility; the linkage between our Conflict Minerals compliance processes and our broader Ethics and Compliance processes is described in our Conflict Minerals Policy).

 

   

We have issued an annual Teradata Corporate Social Responsibility (“CSR”) Report (which includes reference to our Conflict Minerals policy and program, supply chain integrity initiatives and initiatives to support and help protect human rights) and posted it for public access on our website (see www.teradata.com/corporate-social-responsibility).

 

   

Teradata has included Conflict Minerals, human rights and third-party due-diligence awareness and compliance in our ethics, compliance and code-of-conduct training for employees and members of our Board of Directors (see www.teradata.com/code-of-conduct and www.teradata.com/corporate-social-responsibility, including the documents linked for the “Teradata Code of Conduct” and the “Teradata Corporate Social Responsibility Report”).

 

   

Teradata has included requirements that Flex and our suppliers comply with our Conflict Minerals Policy in certain relevant specifications and vendor regulatory compliance criteria for our hardware products.

 

   

Teradata has included compliance with Conflict Minerals requirements provisions in certain relevant contracts with our Contract-Manufacturer and/or key suppliers.

 

  B.

Supply Chain Risk Identification and Assessment

 

   

Teradata has communicated with our Contract-Manufacturer regarding Conflict Minerals surveying, tracking, reporting, expectations and upstream key supplier communications with respect to direct suppliers of components for our hardware who have not been identified as solely supplying components that do not contain any 3TG (e.g., plastic, aluminum, packaging, labels, documentation and other non-3TG-containing components).

 

   

Teradata has reviewed our Contract-Manufacturer’s Forms SD and Conflict Minerals Reports in 2019 for products produced in 2018 (see https://www.sec.gov/Archives/edgar/data/816761/000119312519155567/0001193125-19-155567-index.htm); in 2018 for products produced in 2017 (see https://www.sec.gov/Archives/edgar/data/866374/000110465918037147/0001104659-18-037147-index.htm); in 2017 for products it manufactured during 2016 (see https://www.sec.gov/Archives/edgar/data/866374/000110465917034301/a17-13957_1sd.htm), in 2016 for products it manufactured during 2015 (see https://www.sec.gov/Archives/edgar/data/866374/000110465916123371/0001104659-16-123371-index.htm), in 2015 for products it manufactured during 2014 (see https://www.sec.gov/Archives/edgar/data/866374/000110465915042045/0001104659-15-042045-index.htm), and in 2014 for products it manufactured during 2013 (see https://www.sec.gov/Archives/edgar/data/866374/000110465914042967/a14-13522_1sd.htm).

 

   

Teradata has reviewed some (spot-checked) relevant websites, statements, Conflict Minerals Policies and/or Conflict Minerals Reports of some key suppliers regarding their stated Conflict Minerals initiatives, processes, reasonable country of origin inquiry (“RCOI”) processes and due diligence processes.

 

5


   

Teradata has received and reviewed a RMI Conflict Minerals Reporting Template form for 2019 (as well as the years 2013-2018) completed by our Contract-Manufacturer with respect to our hardware products; designed our Conflict Minerals program and actions and determinations related to our Conflict Minerals program described in this Report to materially meet RCOI requirements of the Rule and Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas; Second Edition, including related supplements regarding 3TG.

 

   

Teradata is a participating, membership-fee-supporting member of the RMI (see http://www.conflictfreesourcing.org/about/members-and-collaborations/).

 

   

Teradata has, through our participation in and support of the RMI, helped make Conflict Minerals training, guidance and resources available to our employees, suppliers and others (see http://www.conflictfreesourcing.org/media/flash/conflict-minerals-overview/; http://www.conflictfreesourcing.org/resources-and-training/training/ and http://www.conflictfreesourcing.org/resources-and-training/guidance-documents/).

 

  C.

Reasonable Country of Origin Inquiry (“RCOI”)

Our Contract-Manufacturer reported to us the following with respect to our hardware products manufactured during 2019:

 

   

90 key suppliers of components for our hardware for 2019 were surveyed regarding Conflict Minerals using the RMI framework. 27 of our total 90 key suppliers were not surveyed because it was determined that they solely provide components or materials that do not to contain any 3TG at all or are outside the scope of the Rule, such as components or materials that are solely plastic, non-metallic fasteners, aluminum, packaging, test media, documentation, ink or a label; and

 

   

as of April 23, 2020, of the 90 key suppliers surveyed, 12 of the responses of those key suppliers for 2019 were deemed complete, 40 were open (e.g., awaiting responses or supplemental responses), 11 were rejected or repeated (e.g., identity of smelter or refiner not provided or deemed to be invalid) and none had some other identified problem (e.g., response in a form other than through the CMRT).

The RMI CMRT completed by our sole-source Contract-Manufacturer and provided to us for 2019 regarding our hardware products includes the following as of April 23, 2020:

 

   

each of the Subject Minerals is intentionally included in Teradata’s hardware products;

 

   

each of the Subject Minerals is necessary to the production of Teradata’s hardware products and contained in our hardware products;

 

   

some of the tantalum, tin and tungsten in Teradata’s hardware products originates from the Covered Countries;

 

   

it is unknown if any of the gold in Teradata’s hardware products originates from the Covered Countries;

 

   

100% of the Subject Minerals in Teradata’s hardware products do not originate from recycled or scrap sources;

 

   

Conflict Minerals data/information has not yet been received from 100% of suppliers of 3TG used in Teradata’s hardware;

 

   

all smelters of the Subject Minerals in Teradata’s hardware products have not yet been identified for all of the Subject Minerals;

 

6


   

all applicable smelter information received by Teradata’s Contract-Manufacturer has been reported in its CMRT declaration that was provided to us;

 

   

Teradata’s Contract-Manufacturer has a policy in place that addresses Conflict Minerals sourcing, and that policy is publicly available on Flex’s website at https://flex.com/-/media/Project/Flex/BrandSite/other-pdf/supplier-information/supplier-quality/Responsible_Sourcing_
Policy_2018.pdf?revision=58874505-529c-4b5a-890a-4ca2e3cb91d1
;

 

   

Among other things, under Flex’s Conflict Minerals sourcing policy, Flex:

 

     

expects that its suppliers source from socially responsible suppliers;

 

     

expects that its suppliers have policies and procedures in place to ensure that products and parts supplied to Flex are DRC conflict-free;

 

     

expects that its suppliers provide all necessary due diligence information to confirm that all Conflict Minerals supplied to Flex are DRC conflict-free;

 

     

expects that its suppliers pass these requirements on to their supply chain; and

 

     

states that compliance with these requirements are taken into consideration when selecting and retaining suppliers.

In connection with that CMRT, our Contract-Manufacturer provided us with information regarding 264 smelters/refiners/sources of the Subject Minerals included during 2019 in our hardware products as identified in direct supplier surveys. Annex I of this Report includes a list of source countries for each of the Subject Minerals identified through that process. The information provided by our Contract-Manufacturer correspondingly identifies the following for each of the Subject Minerals as of April 23, 2020:

 

   

Gold – 105 smelters/refiners/sources of recycled, scrap and mined gold, sourced from 34 countries;

 

   

Tantalum – 40 smelters/refiners/sources of recycled, scrap and mined tantalum sourced from 12 countries;

 

   

Tin – 77 smelters/refiners/sources of recycled, scrap and mined tin sourced from 15 countries; and

 

   

Tungsten – 42 smelters/refiners/sources of recycled, scrap and mined tungsten sourced from 11 countries.

Of the 105 identified gold smelters/refiners/sources, 104 (99%) were listed as RMAP conformant, and 1 (1%) was not RMAP listed — for a total RMAP conformant/active rate for identified sources of gold in our supply chain of 99%.

Of the 40 identified tantalum smelters/refiners/sources, 39 (98%) were listed as RMAP conformant, and 1 (2%) was not RMAP listed — for a total RMAP conformant/active rate for identified sources of tantalum in our supply chain of 98%.

Of the 77 identified tin smelters/refiners/sources, 76 (99%) were listed as RMAP conformant, and 1 (1%) was not RMAP listed — for a total RMAP conformant/active rate for identified sources of tin in our supply chain of 99%.

Of the 42 identified tungsten smelters/refiners/sources, 41 (98%) were listed as RMAP conformant, and 1 (2%) was listed as RMAP active — for a total RMAP conformant/active rate for identified sources of tungsten in our supply chain of 100%.

Thus, of the 264 total identified smelters/refiners/sources of the Subject Minerals, 260 (98%) were listed as RMAP conformant, 1 (<1%) was listed as RMAP active and 3 (1%) were not RMAP listed — for a total RMAP conformant/active rate for identified sources of the Subject Minerals in our supply chain of 99%.

 

7


Teradata subsequently spot-checked RMI/RMAP data regarding our key suppliers for adverse discrepancies and red flags versus the information and data reported to us by our Contract Manufacturer. We did not detect any adverse discrepancies or red flags from this spot-check. The actions and determinations relevant to RCOI set forth above in this Report, the information in Annex I, the information provided to us by our Contract-Manufacturer from which we derived the information in Annex I, our review of that information, and the immediately preceding paragraph reflect and summarize our RCOI process and results for our hardware products manufactured during 2019.

 

  D.

Teradata’s Responses to Identified Risks

In connection with the CMRT for 2019 from our Contract-Manufacturer and as of April 23, 2020, our Contract-Manufacturer identified to us 22 smelters/refiners/sources for the Subject Minerals included in our hardware products that reportedly source, or reportedly might source, directly and/or indirectly, 3TG from mines or sources in the Covered Countries. Those smelters/refiners/sources are listed in Annex II of this Report. Included are 13 smelters/refiners of tantalum, 2 smelters/refiners of tin, 5 smelters/refiners of tungsten, and 2 smelters/refiners of gold. All 22 of those smelters (100%) have been identified as being DRC conflict-free for their respective Subject Minerals, in accordance with the RMI/RMAP protocols. Thus, the total RMAP conformant rate for identified sources of the Subject Minerals in our supply chain originating from the Covered Countries is 100%.

We subsequently spot-checked RMI/RMAP data regarding these smelters/refiners of DRC-sourced 3TG for adverse discrepancies and red flags versus the information and data reported to us by our Contract Manufacturer. We did not detect any adverse discrepancies or red flags from this spot-check. The actions and determinations relevant to Conflict Minerals due diligence set forth above, the information in Annex II, the information provided to us by both RMI and our Contract-Manufacturer from which we derived the information in Annex II, our review of that information, and the immediately preceding paragraph summarize our Conflict Minerals due diligence process and results for our hardware products manufactured during 2019.

 

  E.

Continued Risk Mitigation

Teradata continues to build upon our Conflict Minerals program attributes and activities set forth in this Report. Specifically, during 2019:

 

   

All smelters/refiners identified by our Contract-Manufacturer to us that reportedly source, or reportedly might source, directly or indirectly, 3TG from mines or sources in the Covered Countries were on the RMAP conformant list for 2019.

 

   

The total number of identified smelters/refiners/sources for the Subject Mineral increased slightly (3.5%) from 255 in 2018 to 264 in 2019 but has decreased significantly from 322 in 2016.

 

   

The number of key suppliers increased from 81 in 2018 to 90 in 2019 but has decreased from 94 in 2015 and 101 in 2014.

 

   

Teradata increased the percentage of total key suppliers which were surveyed during the year: 64% surveyed for 2018 and 70% for 2019.

 

   

Teradata continued to include compliance with our Conflict Minerals Policy, the principles of the RBA Code of Conduct and the principles of the UN Global Compact in our Code of Conduct, Supplier Code of Conduct and Business Partner Code of Conduct during 2019 and included information about each of those items in our annual all-employee ethics and compliance training for 2019.

 

   

We continue to report relevant information regarding Conflict Mineral requirements, compliance and status to our senior management and the Audit Committee of our Board of Directors.

 

   

Teradata further monitored legal developments and guidance related to Conflict Mineral compliance during 2019 and considered and applied relevant developments to our Conflict Minerals program.

 

8


   

We continue to assess, with assistance from subject-matter-experts from an outside consulting firm, independent private sector audit (IPSA) readiness requirements and criteria for application to our Conflict Minerals program, should such undertakings become legally required in the future.

 

   

Teradata maintains and supplements information and materials on our internal employee Conflict Minerals online resource and collaboration site.

 

   

We maintain inquiries regarding Conflict Minerals as part of our compliance due diligence questionnaire template for merger-and-acquisition candidates.

 

   

Teradata continues to be a member of the RMI and financially support the RMI through paying our RMI membership-fees.

 

   

By becoming a member of the RMI starting in 2015, Teradata gained deeper direct access to RMI participant data, enabling us to take measures to verify related data reported to us by our Contract Manufacturer and to review relevant data to look for red flags and indicia of risks, rather than relying solely on our Contract-Manufacturer to do so and report such to us.

 

9


ANNEX I

To Teradata Corporation

Conflict Minerals Report

For the Year Ended December 31, 2019

IDENTIFIED COUNTRIES/PLACES OF ORIGIN FOR CONFLICT MINERALS

Recycled, Scrap and Mines

 

Gold (34)    Tantalum (12)    Tin (15)    Tungsten (11)

Andorra

Australia

Austria

Belgium

Brazil

Canada

Chile

China

France

Germany

India

Indonesia

Italy

Japan

Kyrgyzstan

Kazakhstan

Mexico

Netherlands

Philippines

Poland

Russia

Singapore

South Africa

Spain

Switzerland

Sweden

Republic of Korea

Russia

Taiwan

Thailand

Turkey

United States of America

United Arab Emirates

Uzbekistan

  

Brazil

China

Estonia

Germany

India

Japan

Kazakhstan

Macedonia

Mexico

Russia

Thailand

United States of America

  

Belgium

Bolivia

Brazil

China

Indonesia

Japan

Malaysia

Peru

Philippines

Poland

Spain

Thailand

Taiwan

United States of America

Vietnam

  

Austria

Brazil

China

Germany

Japan

Philippines

Republic of Korea

Russia

Taiwan

United States of America

Vietnam

 

10


ANNEX II

To Teradata Corporation

Conflict Minerals Report

For the Year Ended December 31, 2019

IDENTIFIED POSSIBLE SMELTERS/REFINERS/SOURCES OF CONFLICT MINERALS FROM THE DRC REGION

 

Smelter/Refiner Name

  

Location

  

Smelter ID Number

  

RMAP Compliance Status (as
listed at conflictfreesourcing.org)

Tantalum (13)         
Asaka Riken Co., Ltd.    Japan    CID000092    Conformant
F&X Electro-Materials Ltd.    China    CID000460    Conformant
Global Advanced Metals Boyertown    USA    CID002557    Conformant
Guangdong Zhiyuan    China    CID000616    Conformant
New Materials Co., Ltd.         
H.C. Starck Ltd.    Thailand    CID002544    Conformant
H.C. Starck Tantalum and Niobium         
GmbH & Co.    Germany    CID002545    Conformant
H.C. Starck Smelting GmbH & Co. KG    Germany    CID002550    Conformant
Hengyang King Xing Lifeng         
New Materials Co., Ltd.    China    CID002492    Conformant
NPM Silmet AS    Estonia    CID001200    Conformant
Ningxia Orient Tantalum         
Industry Co, Ltd.    China    CID001277    Conformant
Power Resources Ltd.    Macedonia    CID002847    Conformant
Taki Chemical Co., Ltd.    Japan    CID001869    Conformant
Ulba Metallurgical Plant JSC    Kazakhstan    CID001969    Conformant
Tin (2)         
Malaysia Smelting Corporation    Malaysia    CID001105    Conformant
Thaisarco    Thailand    CID001898    Conformant
Tungsten (5)         
Global Tungsten & Powders Corp.    USA    CID000568    Conformant
Niagara Refining LLC    USA    CID002589    Conformant
Masan Tungsten Chemical LLC (MTC)    Vietnam    CID002543    Conformant

 

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Smelter/Refiner Name

  

Location

  

Smelter ID Number

  

RMAP Compliance Status (as
listed at conflictfreesourcing.org)

Wolfram Bergbau und Hütten AG    Austria    CID002044    Conformant
Xiamen Tungsten (H.C.) Co., Ltd.    China    CID002320    Conformant
Gold (2)         
Emirates Gold DMCC    United Arab Emirates    CID002561    Conformant
L’Orfebre S.A.    Andorra    CID002762    Conformant

 

12