UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

 

FORM SD

 

SPECIALIZED DISCLOSURE REPORT

 

 

 

AVNET, INC.

(Exact name of registrant as specified in its charter)

 

New York   1-4224   11-1890605
(State or other jurisdiction   (Commission File Number)   (IRS Employer
of incorporation or organization)       Identification No.)

 

2211 South 47th Street, Phoenix, Arizona   85034
(Address of principal executive offices)   (Zip Code)

 

Joy Newborg

Associate General Counsel

(480) 643-2000

(Name and telephone number, including area code,

of the 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:

 

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-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

 

This Specialized Disclosure Report on Form SD and the Conflict Minerals Report, filed as Exhibit 1.01, is filed by Avnet, Inc. (collectively with its consolidated subsidiaries, the “Company”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Conflict Minerals Rule”), for the calendar year ended December 31, 2021, and is posted on the Company’s website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals. Information contained on, or accessible through, the Company’s website is neither part of nor incorporated by reference into this Report.

 

Item 1.02 Exhibit

 

The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.

 

Section 2 – Exhibits

 

Item 2.01 Exhibits

 

Exhibit
Number
  Description
     
1.01   Conflict Minerals Report for the calendar year ended December 31, 2021.

 

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SIGNATURE

 

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.

 

Date: May 26, 2022 By: /s/ Thomas Liguori
 

Thomas Liguori

Chief Financial officer

 

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Exhibit 1.01

 

 

CONFLICT MINERALS REPORT

 

For the Reporting Period from January 1 to December 31, 2021

 

Introduction

 

This is the Conflict Minerals Report of Avnet, Inc. for the calendar year 2021 (“Report”), which has been filed as an exhibit to the Company’s Form SD as provided for in Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”) and is posted on the Company’s website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals. Information contained on, or accessible through, the Company’s website is neither part of nor incorporated by reference into this Report. The date of filing of this Report is May 26, 2022.

 

References in this Report to “the Company,” “Avnet,” “we,” “our,” or “us” means Avnet, Inc. together with its subsidiaries, except where the context otherwise requires.

 

Applicability of the Conflict Minerals Rule to Avnet

 

Avnet is a global technology distributor and solutions provider that supports customers at every stage of the product lifecycle, from idea to design and from prototype to production. Its unique position at the center of the technology value chain enables it to accelerate the design and supply stages of product development so customers can realize revenue faster. A core part of Avnet’s business is as a global distributor of electronic components. It markets, sells and distributes electronic components from the world’s leading electronic component manufacturers, including semiconductors, IP&E components (interconnect, passive and eletromechanical), and other integrated and embedded components, and distributes a comprehensive portfolio of kits, tools, industrial automation components, and test and measurement products. It also provides embedded solutions, such as technical design, integration and assembly of embedded products, systems, and solutions; provides integrated solutions for embedded display solutions, such as touch and passive displays; and develops and produces standard board, industrial subsystems and application-specific devices.

 

The Conflict Minerals Rule requires that the Company disclose in an annual Form SD and associated Conflict Minerals Report information regarding any conflict minerals that are “necessary to the functionality or production” of any product that it manufactures or contracts to be manufactured. The Securities and Exchange Commission (“SEC”) defines conflict minerals as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten (collectively, “CMs”). The Democratic Republic of Congo and its adjoining countries have extensive reserves of CMs, some of which are illegally sourced and traded by armed groups who are responsible for significant human rights violations. The purpose of the Conflict Minerals Rule is to encourage companies whose products contain CMs to endeavor to source from suppliers who do not directly or indirectly support such armed groups through their purchasing decisions. The term CM refers to the named minerals and their derivatives, and does not infer that the procurement of such minerals or derivatives directly or indirectly financed or benefitted armed groups in the Democratic Republic of Congo or an adjoining country. CMs are used in many electronic components and computer products.

 

Avnet’s revenues for 2021 were largely from distribution and services that were not in-scope for purposes of compliance with the Conflict Minerals Rule. However, it manufactured or contracted to manufacture certain products in which CMs were necessary to the functionality or production of those products during 2021 (collectively, “Covered Products”). Therefore, the Company conducted a reasonable country of origin inquiry (“RCOI”), in good faith, to determine whether any of the CMs in the Covered Products: (1) originated in the Democratic Republic of Congo or an adjoining country, including Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia (collectively, the “Covered Countries”); or (2) are from recycled or scrap sources. Please see “Conflict Minerals Program – Reasonable Country of Origin Inquiry” for more information on the RCOI.

 

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The Company conducted further due diligence on the source and chain of custody of such CMs that conformed, in all material respects, to an internationally recognized due diligence framework as required by the Conflict Minerals Rule. Please see “Conflict Minerals Program – Design of Conflict Minerals Program” for more information on the design of the due diligence program and “Conflict Minerals Program – Due Diligence Efforts” for more information on the due diligence conducted.

 

Avnet is a downstream consumer of CMs. It does not purchase the necessary CMs contained in its Covered Products directly from mines, smelters or refiners and is generally many levels removed from such market participants. Through the efforts described in this Report, Avnet seeks to ensure that its sourcing practices are consistent with its Responsible Minerals Sourcing Policy and to encourage conflict free sourcing in its supply chain.

 

Responsible Minerals Sourcing Policy

 

Avnet is committed to responsible sourcing of CMs and promotes traceability of CMs and transparency of its global supply chain. It supports the efforts of the Responsible Business Alliance’s (“RBA”) due diligence and reporting processes that seek to ensure supply chain transparency. In addition, the Company has actively engaged with its customers and suppliers for several years with respect to the use of CMs, and has adopted a Responsible Minerals Sourcing Policy, which has been communicated to Avnet’s suppliers and the public. The Responsible Minerals Sourcing Policy is below:

 

Avnet, Inc., including its subsidiaries (collectively “Avnet”), is committed to source minerals responsibly and avoid sourcing minerals that contribute to armed conflict or human rights abuses in conflict affected and high-risk areas (CAHRAs), including the Democratic Republic of Congo (DRC) or adjoining countries. Avnet’s approach is to promote the traceability and transparency of supply chains and move towards a conflict-free global supply chain.

 

Avnet supports the aims of the Responsible Business Alliance’s Responsible Minerals Initiative (RMI) to identify, reduce and eventually eliminate the use of conflict minerals that finance or benefit conflict or human rights violations, and the Responsible Minerals Assurance Process (RMAP) to validate responsible sources. Avnet encourages its suppliers to likewise support such efforts. “Conflict minerals” include tantalum, tin, tungsten and gold, which are used in many electronic components and computer products.

 

Under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the U.S. Securities and Exchange Commission (“SEC”) rules, Avnet is required to annually report on Form SD whether products it manufactures or contracts to manufacture contain conflict minerals necessary to the functionality or production of the products, which have been sourced from mines in the DRC or adjoining countries (“covered products”). Revenue from the mining and trade of conflict minerals from the DRC or adjoining countries is believed to finance or benefit armed groups that are responsible for human rights violations.

 

Avnet is a global technology distributor and solutions provider. To a very limited extent Avnet manufactures or contracts to manufacture products, some of which are covered products. However, Avnet is a downstream consumer of conflict minerals. It does not purchase directly from mines, smelters or refiners and is many levels removed from such market participants. Avnet endeavors to avoid purchasing products containing conflict minerals sourced from CAHRAs that directly or indirectly finance or benefit armed groups, while minimizing unintended consequences of de facto embargoes for conflict-free mines. Avnet also expects its suppliers to source minerals only from responsible sources.

 

Avnet annually conducts a reasonable country of origin inquiry (RCOI) and due diligence that aligns with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Framework). As a downstream consumer, Avnet expects its suppliers to provide proper verification of the country of origin and source of the conflict minerals used in the products they supply to Avnet, utilizing the most current Conflict Minerals Reporting Template (CMRT) developed by RMI. Avnet also encourages its suppliers to adopt similar policies, due diligence frameworks, and management systems with respect to responsible minerals sourcing to drive those efforts throughout their supply chain.

 

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The Responsible Minerals Sourcing Policy is available on the Company’s website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals.

 

Conflict Minerals Program

 

Design of Conflict Minerals Program

 

Avnet’s 2021 Conflict Minerals Program (“2021 Program”) utilized the internationally recognized framework The Organization for Economic Co-Operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Framework”) to develop its process to identify the country of origin and chain of custody of the CMs.

 

As Avnet does not purchase CMs directly from any mine, refiner or smelter, its supply chain with respect to the CMs in its Covered Products is highly complex and there are many parties in the supply chain between Avnet’s direct supplier and the mine from which the CM originated. Due to the Company’s “downstream” position in the supply chain, it followed the principles outlined in the OECD Framework for downstream companies with no direct relationships to smelters or refiners. Therefore, Avnet must rely, in good faith, on its direct suppliers to provide it with information regarding the country of origin and chain of custody of the CMs included in the Covered Products and on third-party audit programs. It is likely that years of engagement and propagation of expectations through many tiers of the supply chain will be necessary before information returned to downstream companies, such as Avnet, may be considered accurate and complete.

 

Covered Products

 

Avnet determined that the following products it manufactured or contracted to manufacture in 2021 contained CMs necessary to the functionality or production of those products, which are referred to as the Covered Products:

 

Electromechanical solutions manufactured or contracted to be manufactured by DEM Manufacturing.

 

Test tools for development engineers incorporating wireless charging functionality using the Wireless Power Consortium  “Qi” technology contracted to be manufactured for AVID.

 

Semi-conductor electronic devices designed and contracted to be manufactured by Avnet per customer specifications.

 

Electronic boards, electronic devices and display solutions manufactured or contracted to be manufactured by Avnet Embedded GmbH and put on the market under the brand “MSC”.

 

Control boards and Human-Machine Interfaces (HMIs) contracted to be manufactured.

 

Server based products integrated from customer designed and/or off-the-shelf components by Avnet Integrated.

 

Design kits manufactured or contracted to be manufactured by Avnet.

 

Sphere module and development kit, Sphere Guardian products, and IOT Gateway products designed by Avnet IoT team and manufactured or contracted to be manufactured by Avnet Products & Emerging Technologies.

 

Development boards and design kits manufactured or contracted to be manufactured by Avnet Silica.

 

Development boards manufactured or contracted to be manufactured by EBV Elektronik.

 

Development boards and accessories contracted to be manufactured by Avnet.

 

Covered Products do not include products that were not entered into the stream of commerce in 2021, and do not include products manufactured or contracted to be manufactured by entities acquired by Avnet after April 2021, as provided by the Conflict Minerals Rule.

 

Reasonable Country of Origin Inquiry

 

Pursuant to the Conflict Minerals Rule, Avnet conducted a RCOI on the source and chain of custody of the CMs in its Covered Products, to determine whether any of the necessary CMs in its Covered Products originated in any of the Covered Countries and may not have come from recycled or scrap sources. To the extent applicable, Avnet conducted its RCOI utilizing the same processes and procedures that it established for conducting its due diligence, in particular Steps 1 and 2 of the OECD Framework, which are described under “Due Diligence Efforts” below.

 

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The 2021 RCOI included 454 suppliers (“Suppliers”) that Avnet identified as possibly providing it with components, parts or products that contained the necessary CMs for its Covered Products. These Suppliers identified smelters and refiners that may have processed the necessary CMs contained in the Covered Products. Such smelters and refiners were compared against the Smelter Look-up tab of the Conflict Minerals Reporting Template (“CMRT”) and the list of “conformant” smelters and refiners and country of origin information published by the RBA’s Responsible Minerals Initiative (“RMI”) to validate the smelters and refiners, which validated facilities are listed in Appendix A, and to determine the countries from where such validated facilities may have obtained CMs, which countries are listed in Appendix B. For this process, Avnet utilized the data its Suppliers provided on their CMRTs version 6.10 or higher along with RMI’s due diligence of smelters and refiners and audits under the Responsible Minerals Assurance Process (“RMAP”) standard. The RMAP uses an independent third-party audit of smelter and refiner management systems and sourcing practices to validate conformance with RMAP protocols and current global standards.

 

The Company retained Assent Compliance (“Assent”), a third-party service provider, to assist in the collection and review of Supplier CMRTs and the identification of risks in the supply chain. During the 2021 RCOI, Avnet contacted Suppliers via the Assent Compliance Manager (“ACM”), a software-as-a-service platform that enables users to manage and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. ACM provides functionality that meets the OECD Framework process expectations by evaluating the quality of each Supplier’s response and assigning a health score based on the Supplier’s declaration of process engagement. Additionally, the results provided in this Report, as well as the step-by-step process for Supplier engagement and upstream due diligence investigations performed, are managed through ACM.

 

Avnet requested that all Suppliers complete a CMRT. On behalf of Avnet, Assent offered training and educational resources to Suppliers to guide them on best practices, completion of a CMRT and the use of the ACM platform. Avnet monitored and tracked all communications in ACM for future reporting and transparency. If a Supplier remained unresponsive after three requests through ACM, Avnet may directly follow-up with such Supplier.

 

Supplier CMRTs are subjected to an automated data validation process, with the goal to increase the completeness and accuracy of submissions and identify any contradictory answers in a CMRT. This data validation process is based on questions within the declaration tab of the CMRT, which helps to identify areas that require further classification or risk assessment as well as to understand the due diligence efforts of the Suppliers. Data validation contributes to the health assessment of Avnet’s Conflict Minerals Program, and the results are shared with Suppliers regarding areas that require clarification or improvement.

 

Submitted Supplier CMRTs are accepted and classified as either valid or invalid. If a Supplier’s CMRT is classified as invalid, the Supplier is provided feedback and guidance on how to correct the validation errors and requested to re-submit a valid CMRT. In addition, Suppliers are provided training courses and direct engagement help through Assent’s multilingual Supplier Experience team.

 

Due Diligence Efforts

 

Based on the findings of the 2021 RCOI, pursuant to the Conflict Minerals Rule, Avnet conducted further due diligence on the source and chain of custody of the CMs in its Covered Products. The Company designed its due diligence measures to conform, in all material respects, with the OECD Framework, which contains a five-step structure for due diligence as a basis for responsible global supply chain management of CMs from conflict-affected and high-risk areas.

 

1.     Establish strong company management systems

 

Avnet has a governance team and a working team to carry out its Conflict Minerals Program. The governance team is responsible for ensuring that the program meets regulatory requirements and enterprise goals and provides direction to the working team. The working team is responsible for the day-to-day execution of the program, diligence efforts and risk mitigation strategy.

 

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Avnet utilizes a third-party service provider, Assent, to assist with collecting and evaluating supply chain information, identifying potential risks and developing additional due diligence steps. Please see “Conflict Minerals Program – Reasonable Country of Origin Inquiry” for more information on the utilization of Assent and its software platform ACM.

 

Avnet has a Responsible Minerals Sourcing Policy, as discussed earlier in this Report. Pursuant to this policy, Avnet expects its Suppliers to source CMs only from responsible sources and to provide proper verification of the country of origin and source of the materials used in the products they supply to Avnet. Suppliers either receive a copy of the policy or are notified of this policy. In addition, the policy is posted on Avnet’s website.

 

Avnet seeks to include CM related provisions in new or amended supplier agreements with respect to the Covered Products. Its current form of supplier agreement contains a CM provision that requires a Supplier to warrant that any products it supplies containing CMs either does not finance or benefit armed groups in the Covered Countries or are from recycled or scrap sources.

 

Avnet utilizes the current CMRT version developed by RMI to identify smelters and refiners in its supply chain. The CMRT requires Suppliers to provide information concerning the usage and source of CMs in their components, parts and products, as well as information concerning their related compliance efforts, including whether they have a policy on conflict-free sourcing and required their own suppliers to source CMs from responsible sources.

 

By utilizing Assent, Avnet provides its Suppliers access to a free platform to upload their CMRTs, help desk support, educational resources on how to properly complete and submit a CMRT, and other multilingual resources.

 

Employees, vendors, suppliers, customers and any third-party can confidentially report concerns regarding Avnet’s business operations, including compliance with the Responsible Minerals Sourcing Policy, through the Ethics Alertline, via phone or internet. Violations or grievances at the industry level can be reported to the RMI directly at http://responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/.

 

Avnet has a document retention policy to retain CM related documents, including supplier responses to CMRTs and the sources identified within each reporting period, for at least five years.

 

2.     Identify and assess risk in the supply chain

 

Avnet identifies the business segments that manufacture or contract to manufacture products reasonably believed to contain CMs and determine the Covered Products subject to the Conflict Minerals Rule. As a global value-added distributor, a significant percentage of Avnet’s operations are out of scope of the Conflict Minerals Rule.

 

Avnet identifies the active suppliers of materials, components, parts, and products that may contain CMs for the Covered Products, and each Supplier is requested to complete the then latest revision of the CMRT. Avnet expects its direct Suppliers to survey their suppliers.

 

Supplier level risks include non-responsive suppliers. Avnet tracks receipt of Supplier CMRTs, and if a Supplier remains unresponsive after three requests through the ACM platform, Avnet directly follows-up with such Supplier. Follow-up with non-responsive Suppliers continued into 2022.

 

Submitted CMRTs go through a data validation process to evaluate responses for plausibility, completion and consistency to lower the risks associated with Supplier CMRT content and for predetermined red flag indicators defined in the OECD Framework to identify risks to the supply chain posed by smelters. To the extent that a CMRT is incomplete, invalid or other relevant information is not provided by a Supplier, follow-up procedures are undertaken to request compliance and to offer feedback, guidance and educational resources. Follow-up with such Suppliers continued into 2022.

 

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Based on a Supplier’s submitted CMRT, the strength of a Supplier’s related compliance efforts, including whether it has a conflict minerals sourcing policy or implements due diligence measures for conflict free sourcing, is evaluated, tracked and rated as either weak or strong.

 

Supplier level risks also include Supplier CMRTs that are based on company-level information versus Covered Product-level information. Suppliers may have been over-inclusive if their suppliers provide information on a company-level basis and under-inclusive if Suppliers experience non-responsive suppliers or incomplete supplier CMRTs. Therefore, the Company is unable to determine if the smelters and refiners listed in Appendix A were all utilized or is a complete list of smelters and refiners utilized for CMs in the Covered Products.

 

Smelters and refiners identified in the CMRTs are compared against the Smelter Look-up tab of the CMRT and the list of Conformant smelters and refiners and country of origin information published by the RMI to determine if the smelter had been audited against a standard in conformance with the OECD Framework, such as RMAP.

 

If a smelter’s due diligence practices have not been audited against the RMAP standard or the smelter is considered non-conformant by RMAP, Assent conducts follow-ups with suppliers reporting those facilities and the facilities are assessed for potential sourcing risks.

 

3.     Design and implementation of a strategy to respond to identified risks

 

Avnet has a risk management plan through which the Conflict Minerals Program is implemented, managed and monitored. The plan includes processes to assess and respond to the risks identified in the supply chain, which are described in more detail under “Due Diligence Efforts – 2. Identify and assess risk in the supply chain”.

 

Working team leaders monitor and report on risk to certain members of senior management.

 

Avnet’s Responsible Minerals Sourcing Policy publicly announces its expectations that Suppliers participate in Avnet’s due diligence process by providing proper verification of the country of origin and source of the materials used in the Covered Products they supply to Avnet. The policy also states that Suppliers are expected to source CMs only from responsible sources.

 

Avnet seeks to include CM related provisions in new or amended supplier agreements with respect to the Covered Products and include CM related due diligence in acquisition activities.

 

Avnet works with Suppliers on an as-needed basis to assist them with understanding the requirements of the Conflict Minerals Rule. Avnet also offers, through Assent, training and educational resources to Suppliers to guide them on best practices, completion of a CMRT and the use of the ACM platform.

 

Avnet has processes in place for new product introductions and changes to the bill of materials for the Covered Products to help ensure compliance with the Conflict Minerals Program.

 

Avnet participates in Assent’s smelter outreach initiative, where letters are sent twice a year to each smelter and refiner not conformant or not enrolled in RMAP to encourage participation in a cross-recognized industry audit program. The initiative also includes letters to smelters and refiners who are conformant to RMAP to reflect appreciation for their efforts.

 

Employees, vendors, suppliers, customers and any third-party can confidentially report concerns regarding Avnet’s business operations, including compliance with the Responsible Minerals Sourcing Policy, through the Ethics Alertline, via phone or internet.

 

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4.     Carry out independent third-party audit of supply chain due diligence

 

As Avnet is a downstream consumer of CMs and is generally many steps removed from smelters and refiners which provide minerals and ores, Avnet is not positioned to conduct direct audits of smelters and refiners’ due diligence practices. Instead, it relies on initiatives such as those led by RBA, including RMI, to conduct smelter and refinery due diligence audits.

 

5.     Report annually on supply chain due diligence

 

Avnet annually files a Form SD and a Conflict Minerals Report with the SEC and makes them available to the public on its website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals.

 

Results of 2021 Conflict Minerals Program

 

As a downstream purchaser of components, parts and products that may contain CMs, Avnet’s 2021 Program can provide only reasonable, but not absolute, assurance regarding the country of origin and chain of custody of the necessary CMs in its Covered Products.

 

The due diligence process is based on Avnet requesting information from its direct Suppliers, with those Suppliers requesting similar information from their suppliers and so on, up the supply chain, to eventually identify the original sources of the necessary CMs. However, those who purchase CMs directly from smelters or refiners may not be able to discern which of its product lines include specific CMs from each smelter or refiner, and so it is common practice for such purchasers to list all smelters and refiners they may purchase from within the reporting period. Likewise, Suppliers’ CMRTs primarily provided information at the company level, with few at the product level, and Suppliers may have received similar information from their suppliers and so on. Therefore, Avnet must rely, in good faith, on its direct Suppliers to provide it with valid and complete information. Finally, not all Suppliers completed CMRTs or completed CMRTs in full for the 2021 Program.

 

For the 2021 Program, 454 Suppliers were identified, of which 263 (or 57.9%) submitted a completed CMRT.

 

Supplier CMRT Results 
Year of
Program
   # Suppliers in
Scope
   # Completed
CMRTs
   % Completed
CMRTs
   # Valid CMRTs   % Valid CMRTs 
2021    454    263    57.9%    251    55.3% 

 

Strength of Supplier CM Program Results 
Year of
Program
   # Completed
CMRTS
   # Suppliers with
CM programs and
policies rated as
strong
   # Suppliers with
no CMs in their
products
   Total Suppliers with
strong CM
programs/policies or no
CMs in products
   % of such
Suppliers
 
2021    263    193    39    232    88.2% 

 

The 335 legitimate smelters and refiners identified by Suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are listed in Appendix A. Based on the limitations explained above, this list may be more comprehensive than the list of smelters and refiners which actually processed the CMs contained in the Covered Products. The below table summarizes the number of such legitimate smelters and refiners which have been audited, are in the process of being audited, or not enrolled to be audited by RMI utilizing the RMAP standard as well as audit results.

 

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Smelter and Refiner Audit Status Results (1)  
RMI Audit Status  Legitimate Smelters and Refiners 
RMAP Conformant (2)   231    68.96%
RMAP Active (3)   18    5.37%
Non-Conformant (4)   17    5.07%
Not Enrolled (roll up of the statuses below)   69    20.60%
Total   335    100.00%

 

Not Enrolled subcategories  Count 
Communication Suspended - Not Interested(5)   6 
Due Diligence Vetting Process (6)   0 
In Communication (7)   13 
Outreach Required (8)   46 
RMI Due Diligence Review - Unable to Proceed (9)   4 

 

 

 

(1) The compliance status information provided in the table is based solely on information made available by RMI, without independent verification by the Company.

(2) ) “Conformant” means that the smelter or refiner has completed the independent annual audit process and been found to be in conformance with the relevant RMAP standard, whereby verified to have conflict-free sources.

(3) “Active” means that the smelter or refiner is in the process of being independently audited or has committed to begin the audit process but has not yet been determined to be in conformance with the relevant RMAP standard.

(4) “Non-Conformant” means that the smelter or refiner has been independently assessed but found not to be in conformance with the relevant RMAP standard.

(5) “Communication Suspended – Not Interested” means the smelter or refiner has strongly communicated a lack of interest in participating in the audit program.

(6)  “Due Diligence Vetting Process” means the smelter or refiner does not meet RMI’s requirements for participation in the audit program according to the Due Diligence Vetting Process.

(7) “In Communication” means the smelter or refiner is not yet active but is in communications with RMAP and/or a member company.

(8) “Outreach Required” means RMI member companies need to contact entity to encourage their participation in audit program.

(9) “RMI Due Diligence Review – Unable to Proceed” means the smelter or refiner has not met the thresholds for the Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted.

 

The aggregated list of countries of origin from which the reported smelters and refiners may have collectively sourced CMs, based on information provided through the CMRT data collection process and RMAP audits, is provided in Appendix B. Based on the limitations explained above, this list may be more comprehensive than the list of countries from which CMs contained in the Covered Products were actually sourced.

 

After conducting its 2021 Program, and in light of the limitations explained above, Avnet concludes that it is unable to determine the origin of the CMs contained in its Covered Products and unable to determine whether its Covered Products are DRC conflict free.

 

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Steps to be taken in Calendar 2022

 

As Avnet endeavors not to purchase products that contain CMs that directly or indirectly finance or benefit armed groups in the Covered Countries, and in order to mitigate the risk of purchasing such products, it has continued with its Conflict Minerals Program discussed above during calendar year 2022 and specifically plans to pursue the following steps and improvements:

 

Continue to engage with Suppliers that provided incomplete responses or no responses for 2021 to help encourage them to provide requested information for 2022.

 

For Suppliers whose conflict minerals compliance programs and policies are deemed weak, continue to follow-up with such Suppliers to encourage them to improve their efforts and policies.

 

For new in-scope suppliers, to communicate Avnet’s sourcing expectations, including through the dissemination of the Responsible Minerals Sourcing Policy and inclusion of CM sourcing requirements in supplier agreements, and provide access to training and educational resources on the requirements of the Conflict Minerals Rule and to guide them on best practices, completion of a CMRT and the use of the ACM platform.

 

Proactively analyze whether any CMs are present in future products that it develops or in existing products to the extent the materials included in such existing products are revised.

 

Proactively seek to include CM related provisions in new or amended supplier agreements with respect to the Covered Products.

 

Continue to monitor its Ethics Alertline for issues related to the Company’s conflict minerals program.

 

Cautionary Statement about Forward-Looking Statements

 

Certain statements in this Report may be “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. Words such as “expects,” “intends,” “plans,” “believes,” “anticipates” and similar expressions, or the use of future tense, are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to the Company’s future plans, additional steps it intends to take to mitigate the risk that the Company’s necessary CMs benefit armed groups and other statements that do not relate to historical or current facts.

 

Forward-looking statements are based on the Company’s current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict, including: (1) the continued implementation of satisfactory traceability and other compliance measures by Avnet’s direct and indirect suppliers on a timely basis or at all, (2) whether smelters, refiners and other market participants responsibly source CMs and (3) political and regulatory developments regarding CMs. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and the Company undertakes no obligation to update or revise any forward-looking statement, except as required by federal securities law.

 

9

 

 

APPENDIX A

 

List of Smelters and Refiners

 

Avnet utilized data its Suppliers provided on their CMRTs for the 2021 Program along with RBA’s RMI due diligence of smelters and refiners to prepare the below list. The list: (1) may not include all of the smelters and refiners that processed CMs in the Covered Products and (2) may include smelters and refiners which processed CMs which were not contained in the products provided by the Suppliers for the Covered Products.

 

For RMI Audit Status:

(1) “Conformant” means that the smelter or refiner has completed the independent annual audit process and been found to be in conformance with the relevant RMAP standard, whereby verified to have conflict-free sources.

(2) “Active” means that the smelter or refiner is in the process of being independently audited or has committed to begin the audit process but has not yet been determined to be in conformance with the relevant RMAP standard.

(3) “Non-Conformant” means that the smelter or refiner has been independently assessed but found not to be in conformance with the relevant RMAP standard.

(4) “Communication Suspended – Not Interested” means the smelter or refiner has strongly communicated a lack of interest in participating in the audit program.

(5)  “Due Diligence Vetting Process” means the smelter or refiner does not meet RMI’s requirements for participation in the audit program according to the Due Diligence Vetting Process.

(6) “In Communication” means the smelter or refiner is not yet active but is in communications with RMAP and/or a member company.

(7) “Outreach Required” means RMI member companies need to contact entity to encourage their participation in audit program.

(8) “RMI Due Diligence Review – Unable to Proceed” means the smelter or refiner has not met the thresholds for the Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted.

 

Mineral Smelter / Refiner
CID
Smelter / Refiner Name Smelter / Refiner Location RMI Audit Status
Gold CID000015 Advanced Chemical Company United States of America Conformant
Gold CID000019 Aida Chemical Industries Co., Ltd. Japan Conformant
Gold CID000035 Allgemeine Gold-und Silberscheideanstalt A.G. Germany Conformant
Gold CID000041 Almalyk Mining and Metallurgical Complex (AMMC) Uzbekistan Conformant
Gold CID000058 AngloGold Ashanti Corrego do Sitio Mineracao Brazil Conformant
Gold CID000077 Argor-Heraeus S.A. Switzerland Conformant
Gold CID000082 Asahi Pretec Corp. Japan Conformant
Gold CID000090 Asaka Riken Co., Ltd. Japan Conformant
Gold CID000103 Atasay Kuyumculuk Sanayi Ve Ticaret A.S. Turkey Outreach Required
Gold CID000113 Aurubis AG Germany Conformant
old CID000128 Bangko Sentral ng Pilipinas (Central Bank of the Philippines) Philippines Conformant
Gold CID000157 Boliden AB Sweden Conformant
Gold CID000176 C. Hafner GmbH + Co. KG Germany Conformant
Gold CID000180 Caridad Mexico Outreach Required
Gold CID000185 CCR Refinery - Glencore Canada Corporation Canada Conformant

 

10

 

 

Gold CID000189 Cendres + Metaux S.A. Switzerland Conformant
Gold CID000197 Yunnan Copper Industry Co., Ltd. China Outreach Required
Gold CID000233 Chimet S.p.A. Italy Conformant
Gold CID000264 Chugai Mining Japan Conformant
Gold CID000343 Daye Non-Ferrous Metals Mining Ltd. China In Communication
Gold CID000359 DSC (Do Sung Corporation) Korea, Republic of Conformant
Gold CID000401 Dowa Japan Conformant
Gold CID000425 Eco-System Recycling Co., Ltd. East Plant Japan Conformant
Gold CID000493 OJSC Novosibirsk Refinery Russian Federation Non-Conformant
Gold CID000522 Refinery of Seemine Gold Co., Ltd. China Outreach Required
Gold CID000651 Guoda Safina High-Tech Environmental Refinery Co., Ltd. China Outreach Required
Gold CID000671 Hangzhou Fuchunjiang Smelting Co., Ltd. China Outreach Required
Gold CID000689 LT Metal Ltd. Korea, Republic of Conformant
Gold CID000694 Heimerle + Meule GmbH Germany Conformant
Gold CID000707 Heraeus Metals Hong Kong Ltd. China Conformant
Gold CID000711 Heraeus Precious Metals GmbH & Co. KG Germany Conformant
Gold CID000767 Hunan Chenzhou Mining Co., Ltd. China Outreach Required
Gold CID000773 Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. China Outreach Required
Gold CID000778 HwaSeong CJ CO., LTD. Korea, Republic of Communication Suspended - Not Interested
Gold CID000801 Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. China Conformant
Gold CID000807 Ishifuku Metal Industry Co., Ltd. Japan Conformant
Gold CID000814 Istanbul Gold Refinery Turkey Conformant
Gold CID000823 Japan Mint Japan Conformant
Gold CID000855 Jiangxi Copper Co., Ltd. China Conformant
Gold CID000920 Asahi Refining USA Inc. United States of America Conformant
Gold CID000924 Asahi Refining Canada Ltd. Canada Conformant
Gold CID000927 JSC Ekaterinburg Non-Ferrous Metal Processing Plant Russian Federation RMI Due Diligence Review - Unable to Proceed
Gold CID000929 JSC Uralelectromed Russian Federation Non-Conformant
Gold CID000937 JX Nippon Mining & Metals Co., Ltd. Japan Conformant
Gold CID000956 Kazakhmys Smelting LLC Kazakhstan In Communication
Gold CID000957 Kazzinc Kazakhstan Conformant
Gold CID000969 Kennecott Utah Copper LLC United States of America Conformant
Gold CID000981 Kojima Chemicals Co., Ltd. Japan Conformant
Gold CID001029 Kyrgyzaltyn JSC Kyrgyzstan Non-Conformant
Gold CID001032 L'azurde Company For Jewelry Saudi Arabia RMI Due Diligence Review - Unable to Proceed
Gold CID001056 Lingbao Gold Co., Ltd. China Outreach Required

 

11

 

 

Gold CID001058 Lingbao Jinyuan Tonghui Refinery Co., Ltd. China Outreach Required
Gold CID001078 LS-NIKKO Copper Inc. Korea, Republic of Conformant
Gold CID001093 Luoyang Zijin Yinhui Gold Refinery Co., Ltd. China Outreach Required
Gold CID001113 Materion United States of America Conformant
Gold CID001119 Matsuda Sangyo Co., Ltd. Japan Conformant
Gold CID001147 Metalor Technologies (Suzhou) Ltd. China Conformant
Gold CID001149 Metalor Technologies (Hong Kong) Ltd. China Conformant
Gold CID001152 Metalor Technologies (Singapore) Pte., Ltd. Singapore Conformant
Gold CID001153 Metalor Technologies S.A. Switzerland Conformant
Gold CID001157 Metalor USA Refining Corporation United States of America Conformant
Gold CID001161 Metalurgica Met-Mex Penoles S.A. De C.V. Mexico Conformant
Gold CID001188 Mitsubishi Materials Corporation Japan Conformant
Gold CID001193 Mitsui Mining and Smelting Co., Ltd. Japan Conformant
Gold CID001204 Moscow Special Alloys Processing Plant Russian Federation Non-Conformant
Gold CID001220 Nadir Metal Rafineri San. Ve Tic. A.S. Turkey Conformant
Gold CID001236 Navoi Mining and Metallurgical Combinat Uzbekistan Conformant
Gold CID001259 Nihon Material Co., Ltd. Japan Conformant
Gold CID001325 Ohura Precious Metal Industry Co., Ltd. Japan Conformant
Gold CID001326 OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) Russian Federation Non-Conformant
Gold CID001352 PAMP S.A. Switzerland Conformant
Gold CID001362 Penglai Penggang Gold Industry Co., Ltd. China Outreach Required
Gold CID001386 Prioksky Plant of Non-Ferrous Metals Russian Federation Non-Conformant
Gold CID001397 PT Aneka Tambang (Persero) Tbk Indonesia Conformant
Gold CID001498 PX Precinox S.A. Switzerland Conformant
Gold CID001512 Rand Refinery (Pty) Ltd. South Africa Conformant
Gold CID001534 Royal Canadian Mint Canada Conformant
Gold CID001546 Sabin Metal Corp. United States of America Communication Suspended - Not Interested
Gold CID001555 Samduck Precious Metals Korea, Republic of Conformant
Gold CID001562 Samwon Metals Corp. Korea, Republic of Communication Suspended - Not Interested
Gold CID001585 SEMPSA Joyeria Plateria S.A. Spain Conformant
Gold CID001619 Shandong Tiancheng Biological Gold Industrial Co., Ltd. China Outreach Required
Gold CID001622 Shandong Zhaojin Gold & Silver Refinery Co., Ltd. China Conformant
Gold CID001736 Sichuan Tianze Precious Metals Co., Ltd. China Conformant
Gold CID001756 SOE Shyolkovsky Factory of Secondary Precious Metals Russian Federation Non-Conformant
Gold CID001761 Solar Applied Materials Technology Corp. Taiwan, Province of China Conformant

 

12

 

 

Gold CID001798 Sumitomo Metal Mining Co., Ltd. Japan Conformant
Gold CID001810 Super Dragon Technology Co., Ltd. China Outreach Required
Gold CID001875 Tanaka Kikinzoku Kogyo K.K. Japan Conformant
Gold CID001909 Great Wall Precious Metals Co., Ltd. of CBPM China Outreach Required
Gold CID001916 The Refinery of Shandong Gold Mining Co., Ltd. China Conformant
Gold CID001938 Tokuriki Honten Co., Ltd. Japan Conformant
Gold CID001947 Tongling Nonferrous Metals Group Co., Ltd. China Outreach Required
Gold CID001955 Torecom Korea, Republic of Conformant
Gold CID001980 Umicore S.A. Business Unit Precious Metals Refining Belgium Conformant
Gold CID001993 United Precious Metal Refining, Inc. United States of America Conformant
Gold CID002003 Valcambi S.A. Switzerland Conformant
Gold CID002030 Western Australian Mint (T/a The Perth Mint) Australia Conformant
Gold CID002100 Yamakin Co., Ltd. Japan Conformant
Gold CID002129 Yokohama Metal Co., Ltd. Japan Conformant
Gold CID002224 Zhongyuan Gold Smelter of Zhongjin Gold Corporation China Conformant
Gold CID002243 Gold Refinery of Zijin Mining Group Co., Ltd. China Conformant
Gold CID002282 Morris and Watson New Zealand In Communication
Gold CID002290 SAFINA A.S. Czechia Conformant
Gold CID002312 Guangdong Jinding Gold Limited China Outreach Required
Gold CID002314 Umicore Precious Metals Thailand Thailand Conformant
Gold CID002459 Geib Refining Corporation United States of America Conformant
Gold CID002509 MMTC-PAMP India Pvt., Ltd. India Conformant
Gold CID002511 KGHM Polska Miedz Spolka Akcyjna Poland Conformant
Gold CID002515 Fidelity Printers and Refiners Ltd. Zimbabwe RMI Due Diligence Review - Unable to Proceed
Gold CID002516 Singway Technology Co., Ltd. Taiwan, Province of China Conformant
Gold CID002525 Shandong Humon Smelting Co., Ltd. China Outreach Required
Gold CID002527 Shenzhen Zhonghenglong Real Industry Co., Ltd. China Outreach Required
Gold CID002560 Al Etihad Gold Refinery DMCC United Arab Emirates Conformant
Gold CID002561 Emirates Gold DMCC United Arab Emirates Conformant
Gold CID002562 International Precious Metal Refiners United Arab Emirates In Communication
Gold CID002563 Kaloti Precious Metals United Arab Emirates RMI Due Diligence Review - Unable to Proceed
Gold CID002567 Sudan Gold Refinery Sudan Outreach Required
Gold CID002580 T.C.A S.p.A Italy Conformant
Gold CID002582 REMONDIS PMR B.V. Netherlands Conformant
Gold CID002584 Fujairah Gold FZC United Arab Emirates Outreach Required

 

13

 

 

Gold CID002587 Industrial Refining Company Belgium Non-Conformant
Gold CID002588 Shirpur Gold Refinery Ltd. India Outreach Required
Gold CID002605 Korea Zinc Co., Ltd. Korea, Republic Of Conformant
Gold CID002606 Marsam Metals Brazil Conformant
Gold CID002615 TOO Tau-Ken-Altyn Kazakhstan Conformant
Gold CID002708 Abington Reldan Metals, LLC United States of America Non-Conformant
Gold CID002761 SAAMP France Conformant
Gold CID002762 L'Orfebre S.A. Andorra Conformant
Gold CID002763 8853 S.p.A. Italy Conformant
Gold CID002765 Italpreziosi Italy Conformant
Gold CID002778 WIELAND Edelmetalle GmbH Germany Conformant
Gold CID002779 Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH Austria Conformant
Gold CID002850 AU Traders and Refiners South Africa Non-Conformant
Gold CID002852 GCC Gujrat Gold Centre Pvt. Ltd. India Active
Gold CID002853 Sai Refinery India Outreach Required
Gold CID002857 Modeltech Sdn Bhd Malaysia Non-Conformant
Gold CID002863 Bangalore Refinery India Conformant
Gold CID002865 Kyshtym Copper-Electrolytic Plant ZAO Russian Federation Outreach Required
Gold CID002867 Degussa Sonne / Mond Goldhandel GmbH Germany Outreach Required
Gold CID002872 Pease & Curren United States of America Communication Suspended - Not Interested
Gold CID002893 JALAN & Company India Outreach Required
Gold CID002918 SungEel HiMetal Co., Ltd. Korea, Republic Of Conformant
Gold CID002919 Planta Recuperadora de Metales SpA Chile Conformant
Gold CID002973 Safimet S.p.A Italy Conformant
Gold CID003153 State Research Institute Center for Physical Sciences and Technology Lithuania Outreach Required
Gold CID003185 African Gold Refinery Uganda Outreach Required
Gold CID003186 Gold Coast Refinery Ghana Outreach Required
Gold CID003189 NH Recytech Company Korea, Republic of Conformant
Gold CID003324 QG Refining, LLC United States of America Outreach Required
Gold CID003348 Dijllah Gold Refinery FZC United Arab Emirates Outreach Required
Gold CID003382 CGR Metalloys Pvt Ltd. India Outreach Required
Gold CID003383 Sovereign Metals India Outreach Required
Gold CID003421 C.I Metales Procesados Industriales SAS Colombia Active
Gold CID003424 Eco-System Recycling Co., Ltd. North Plant Japan Conformant
Gold CID003425 Eco-System Recycling Co., Ltd. West Plant Japan Conformant
Gold CID003461 Augmont Enterprises Private Limited India Active
Gold CID003463 Kundan Care Products Ltd. India In Communication
Gold CID003487 Emerald Jewel Industry India Limited (Unit 1) India In Communication

 

14

 

 

Gold CID003488 Emerald Jewel Industry India Limited (Unit 2) India In Communication
Gold CID003489 Emerald Jewel Industry India Limited (Unit 3) India In Communication
Gold CID003490 Emerald Jewel Industry India Limited (Unit 4) India In Communication
Gold CID003497 K.A. Rasmussen Norway Outreach Required
Gold CID003500 Alexy Metals United States of America Active
Gold CID003529 Sancus ZFS (L’Orfebre, SA) Colombia Active
Gold CID003540 Sellem Industries Ltd. Mauritania Communication Suspended - Not Interested
Gold CID003548 MD Overseas India In Communication
Gold CID003557 Metallix Refining Inc. United States of America In Communication
Gold CID003575 Metal Concentrators SA (Pty) Ltd. South Africa Conformant
Gold CID003615 WEEEREFINING France Active
Gold CID003617 Value Trading Belgium In Communication
Tantalum CID000211 Changsha South Tantalum Niobium Co., Ltd. China Conformant
Tantalum CID000460 F&X Electro-Materials Ltd. China Conformant
Tantalum CID000616 Guangdong Zhiyuan New Material Co., Ltd. China Conformant
Tantalum CID000914 JiuJiang JinXin Nonferrous Metals Co., Ltd. China Conformant
Tantalum CID000917 Jiujiang Tanbre Co., Ltd. China Conformant
Tantalum CID001076 LSM Brasil S.A. Brazil Conformant
Tantalum CID001163 Metallurgical Products India Pvt., Ltd. India Conformant
Tantalum CID001175 Mineracao Taboca S.A. Brazil Conformant
Tantalum CID001192 Mitsui Mining and Smelting Co., Ltd. Japan Conformant
Tantalum CID001200 NPM Silmet AS Estonia Conformant
Tantalum CID001277 Ningxia Orient Tantalum Industry Co., Ltd. China Conformant
Tantalum CID001508 QuantumClean United States of America Conformant
Tantalum CID001522 Yanling Jincheng Tantalum & Niobium Co., Ltd. China Conformant
Tantalum CID001769 Solikamsk Magnesium Works OAO Russian Federation Conformant
Tantalum CID001869 Taki Chemical Co., Ltd. Japan Conformant
Tantalum CID001891 Telex Metals United States of America Conformant
Tantalum CID001969 Ulba Metallurgical Plant JSC Kazakhstan Conformant
Tantalum CID002492 Hengyang King Xing Lifeng New Materials Co., Ltd. China Conformant
Tantalum CID002504 D Block Metals, LLC United States of America Conformant
Tantalum CID002505 FIR Metals & Resource Ltd. China Conformant
Tantalum CID002506 Jiujiang Zhongao Tantalum & Niobium Co., Ltd. China Conformant
Tantalum CID002508 XinXing HaoRong Electronic Material Co., Ltd. China Conformant
Tantalum CID002512 Jiangxi Dinghai Tantalum & Niobium Co., Ltd. China Conformant

 

15

 

 

Tantalum CID002539 KEMET Blue Metals Mexico Conformant
Tantalum CID002544 H.C. Starck Co., Ltd. Thailand Conformant
Tantalum CID002545 H.C. Starck Tantalum and Niobium GmbH Germany Conformant
Tantalum CID002547 H.C. Starck Hermsdorf GmbH Germany Conformant
Tantalum CID002548 H.C. Starck Inc. United States of America Conformant
Tantalum CID002549 H.C. Starck Ltd. Japan Conformant
Tantalum CID002550 H.C. Starck Smelting GmbH & Co. KG Germany Conformant
Tantalum CID002557 Global Advanced Metals Boyertown United States of America Conformant
Tantalum CID002558 Global Advanced Metals Aizu Japan Conformant
Tantalum CID002707 Resind Industria e Comercio Ltda. Brazil Conformant
Tantalum CID002842 Jiangxi Tuohong New Raw Material China Conformant
Tantalum CID003583 Yancheng Jinye New Material Technology Co., Ltd. China Conformant
Tin CID000228 Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. China Conformant
Tin CID000292 Alpha United States of America Conformant
Tin CID000309 PT Aries Kencana Sejahtera Indonesia Active
Tin CID000402 Dowa Japan Conformant
Tin CID000438 EM Vinto Bolivia (Plurinational State of) Conformant
Tin CID000448 Estanho de Rondonia S.A. Brazil Conformant
Tin CID000468 Fenix Metals Poland Conformant
Tin CID000538 Gejiu Non-Ferrous Metal Processing Co., Ltd. China Conformant
Tin CID000555 Gejiu Zili Mining And Metallurgy Co., Ltd. China Conformant
Tin CID000942 Gejiu Kai Meng Industry and Trade LLC China Non-Conformant
Tin CID001070 China Tin Group Co., Ltd. China Conformant
Tin CID001105 Malaysia Smelting Corporation (MSC) Malaysia Conformant
Tin CID001142 Metallic Resources, Inc. United States of America Conformant
Tin CID001173 Mineracao Taboca S.A. Brazil Conformant
Tin CID001182 Minsur Peru Conformant
Tin CID001191 Mitsubishi Materials Corporation Japan Conformant
Tin CID001231 Jiangxi New Nanshan Technology Ltd. China Conformant
Tin CID001305 Novosibirsk Processing Plant Ltd. Russian Federation Conformant
Tin CID001314 O.M. Manufacturing (Thailand) Co., Ltd. Thailand Conformant
Tin CID001337 Operaciones Metalurgicas S.A. Bolivia (Plurinational State of) Conformant
Tin CID001399 PT Artha Cipta Langgeng Indonesia Conformant
Tin CID001402 PT Babel Inti Perkasa Indonesia Conformant
Tin CID001406 PT Babel Surya Alam Lestari Indonesia Conformant
Tin CID001421 PT Belitung Industri Sejahtera Indonesia Outreach Required
Tin CID001428 PT Bukit Timah Indonesia Conformant
Tin CID001453 PT Mitra Stania Prima Indonesia Conformant
Tin CID001457 PT Panca Mega Persada Indonesia Outreach Required

 

16

 

 

Tin CID001458 PT Prima Timah Utama Indonesia Conformant
Tin CID001460 PT Refined Bangka Tin Indonesia Conformant
Tin CID001463 PT Sariwiguna Binasentosa Indonesia Conformant
Tin CID001468 PT Stanindo Inti Perkasa Indonesia Conformant
Tin CID001477 PT Timah Tbk Kundur Indonesia Conformant
Tin CID001482 PT Timah Tbk Mentok Indonesia Conformant
Tin CID001486 PT Timah Nusantara Indonesia Active
Tin CID001490 PT Tinindo Inter Nusa Indonesia Conformant
Tin CID001493 PT Tommy Utama Indonesia In Communication
Tin CID001539 Rui Da Hung Taiwan, Province of China Conformant
Tin CID001758 Soft Metais Ltda. Brazil Conformant
Tin CID001898 Thaisarco Thailand Conformant
Tin CID001908 Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. China Conformant
Tin CID002015 VQB Mineral and Trading Group JSC Viet Nam Outreach Required
Tin CID002036 White Solder Metalurgia e Mineracao Ltda. Brazil Conformant
Tin CID002158 Yunnan Chengfeng Non-ferrous Metals Co., Ltd. China Conformant
Tin CID002180 Yunnan Tin Company Limited China Conformant
Tin CID002455 CV Venus Inti Perkasa Indonesia Active
Tin CID002468 Magnu's Minerais Metais e Ligas Ltda. Brazil Conformant
Tin CID002478 PT Tirus Putra Mandiri Indonesia Outreach Required
Tin CID002500 Melt Metais e Ligas S.A. Brazil Outreach Required
Tin CID002503 PT ATD Makmur Mandiri Jaya Indonesia Conformant
Tin CID002517 O.M. Manufacturing Philippines, Inc. Philippines Conformant
Tin CID002572 Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company Viet Nam Non-Conformant
Tin CID002573 Nghe Tinh Non-Ferrous Metals Joint Stock Company Viet Nam Outreach Required
Tin CID002574 Tuyen Quang Non-Ferrous Metals Joint Stock Company Viet Nam Outreach Required
Tin CID002696 PT Cipta Persada Mulia Indonesia Conformant
Tin CID002703 An Vinh Joint Stock Mineral Processing Company Viet Nam Outreach Required
Tin CID002706 Resind Industria e Comercio Ltda. Brazil Conformant
Tin CID002756 Super Ligas Brazil Active
Tin CID002773 Metallo Belgium N.V. Belgium Conformant
Tin CID002774 Metallo Spain S.L.U. Spain Conformant
Tin CID002816 PT Sukses Inti Makmur Indonesia Active
Tin CID002834 Thai Nguyen Mining and Metallurgy Co., Ltd. Viet Nam Conformant
Tin CID002835 PT Menara Cipta Mulia Indonesia Conformant
Tin CID002858 Modeltech Sdn Bhd Malaysia Non-Conformant
Tin CID003116 Guangdong Hanhe Non-Ferrous Metal Co., Ltd. China Conformant

17

 

 

Tin CID003190 Chifeng Dajingzi Tin Industry Co., Ltd. China Conformant
Tin CID003205 PT Bangka Serumpun Indonesia Conformant
Tin CID003208 Pongpipat Company Limited Myanmar Outreach Required
Tin CID003325 Tin Technology & Refining United States of America Conformant
Tin CID003356 Dongguan CiEXPO Environmental Engineering Co., Ltd. China Non-Conformant
Tin CID003379 Ma'anshan Weitai Tin Co., Ltd. China Conformant
Tin CID003380 PT Masbro Alam Stania Indonesia Active
Tin CID003381 PT Rajawali Rimba Perkasa Indonesia Conformant
Tin CID003387 Luna Smelter, Ltd. Rwanda Conformant
Tin CID003397 Yunnan Yunfan Non-ferrous Metals Co., Ltd. China Non-Conformant
Tin CID003409 Precious Minerals and Smelting Limited India Non-Conformant
Tin CID003410 Gejiu City Fuxiang Industry and Trade Co., Ltd. China Outreach Required
Tin CID003449 PT Mitra Sukses Globalindo Indonesia Active
Tin CID003486 CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda Brazil Active
Tin CID003524 CRM Synergies Spain Conformant
Tin CID003582 Fabrica Auricchio Industria e Comercio Ltda. Brazil Conformant
Tungsten CID000004 A.L.M.T. Corp. Japan Conformant
Tungsten CID000105 Kennametal Huntsville United States of America Conformant
Tungsten CID000218 Guangdong Xianglu Tungsten Co., Ltd. China Conformant
Tungsten CID000258 Chongyi Zhangyuan Tungsten Co., Ltd. China Conformant
Tungsten CID000281 CNMC (Guangxi) PGMA Co., Ltd. China Outreach Required
Tungsten CID000568 Global Tungsten & Powders Corp. United States of America Conformant
Tungsten CID000766 Hunan Chenzhou Mining Co., Ltd. China Conformant
Tungsten CID000769 Hunan Chunchang Nonferrous Metals Co., Ltd. China Conformant
Tungsten CID000825 Japan New Metals Co., Ltd. Japan Conformant
Tungsten CID000875 Ganzhou Huaxing Tungsten Products Co., Ltd. China Conformant
Tungsten CID000966 Kennametal Fallon United States of America Conformant
Tungsten CID002044 Wolfram Bergbau und Hutten AG Austria Conformant
Tungsten CID002082 Xiamen Tungsten Co., Ltd. China Conformant
Tungsten CID002313 Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. China Communication Suspended - Not Interested
Tungsten CID002315 Ganzhou Jiangwu Ferrotungsten Co., Ltd. China Conformant
Tungsten CID002316 Jiangxi Yaosheng Tungsten Co., Ltd. China Conformant
Tungsten CID002317 Jiangxi Xinsheng Tungsten Industry Co., Ltd. China Conformant
Tungsten CID002318 Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. China Conformant
Tungsten CID002319 Malipo Haiyu Tungsten Co., Ltd. China Conformant
Tungsten CID002320 Xiamen Tungsten (H.C.) Co., Ltd. China Conformant

 

18

 

 

Tungsten CID002321 Jiangxi Gan Bei Tungsten Co., Ltd. China Conformant
Tungsten CID002494 Ganzhou Seadragon W & Mo Co., Ltd. China Conformant
Tungsten CID002502 Asia Tungsten Products Vietnam Ltd. Viet Nam Conformant
Tungsten CID002513 Chenzhou Diamond Tungsten Products Co., Ltd. China Conformant
Tungsten CID002541 H.C. Starck Tungsten GmbH Germany Conformant
Tungsten CID002542 H.C. Starck Smelting GmbH & Co. KG Germany Conformant
Tungsten CID002543 Masan Tungsten Chemical LLC (MTC) Viet Nam Conformant
Tungsten CID002551 Jiangwu H.C. Starck Tungsten Products Co., Ltd. China Conformant
Tungsten CID002589 Niagara Refining LLC United States of America Conformant
Tungsten CID002641 China Molybdenum Co., Ltd. China Conformant
Tungsten CID002645 Ganzhou Haichuang Tungsten Co., Ltd. China Conformant
Tungsten CID002649 Hydrometallurg, JSC Russian Federation Conformant
Tungsten CID002724 Unecha Refractory metals plant Russian Federation Conformant
Tungsten CID002827 Philippine Chuangxin Industrial Co., Inc. Philippines Conformant
Tungsten CID002830 Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. China Conformant
Tungsten CID002833 ACL Metais Eireli Brazil Conformant
Tungsten CID002845 Moliren Ltd. Russian Federation Conformant
Tungsten CID003388 KGETS Co., Ltd. Korea, Republic Of Conformant
Tungsten CID003401 Fujian Ganmin RareMetal Co., Ltd. China Conformant
Tungsten CID003407 Lianyou Metals Co., Ltd. Taiwan, Province of China Conformant
Tungsten CID003408 JSC "Kirovgrad Hard Alloys Plant" Russian Federation Conformant
Tungsten CID003416 NPP Tyazhmetprom LLC Russian Federation Active
Tungsten CID003417 GEM Co., Ltd. China Conformant
Tungsten CID003427 Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. Brazil Active
Tungsten CID003468 Cronimet Brasil Ltda Brazil Conformant
Tungsten CID003553 Artek LLC Russian Federation Outreach Required
Tungsten CID003609 Fujian Xinlu Tungsten China Conformant
Tungsten CID003612 OOO “Technolom” 2 Russian Federation Active
Tungsten CID003614 OOO “Technolom” 1 Russian Federation Active

 

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APPENDIX B

 

Countries of Origin

 

Avnet utilized data its Suppliers provided on their CMRTs for the 2021 Program and relied on information provided by RBA’s RMI due diligence of smelters and refiners regarding the countries of origin and mines or locations of origin to prepare the below list. The list: (1) may not include all of the countries which ultimately sourced the CMs in the Covered Products and (2) may include countries which did not ultimately source CMs contained in the Covered Products.

 

Country of Origin (Material)
Afghanistan Dominica Lithuania Singapore
Åland Islands Dominican Republic Luxembourg Slovakia
Albania Ecuador Madagascar Slovenia
American Samoa Egypt Malaysia South Africa
Andorra Eritrea Mali South Sudan
Angola Estonia Mauritania Spain
Argentina Ethiopia Mexico Sudan
Armenia Finland Mongolia Suriname
Australia France Morocco Sweden
Austria Germany Mozambique Switzerland
Belarus Ghana Myanmar Taiwan
Belgium Guinea Namibia Tajikistan
Bermuda Guyana Netherlands Tanzania
Bolivia (Plurinational State of) Hong Kong New Zealand Thailand
Brazil Hungary Niger Turkey
Bulgaria India Nigeria Uganda
Burundi Indonesia Panama United Arab Emirates
Cambodia Ireland Papua New Guinea United Kingdom
Canada Israel Peru United States
Central African Republic Italy Philippines Uzbekistan
Chile Japan Poland Viet Nam
China Kazakhstan Portugal Zambia
Colombia Kenya Russian Federation Zimbabwe
Congo Korea Rwanda  
Democratic Republic of Congo Kyrgyzstan Saudi Arabia  
Djibouti Liberia Sierra Leone  

 

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