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)
Darrel S. Jackson
Corporate Secretary
(480) 643-2000
(Name and telephone number, including area code,
of the person to contact in connection with thisreport)
Check the appropriate box to indicate the rule pursuant to whichthis 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, 2023.
Section 1 - Conflict MineralsDisclosure
Item 1.01 Conflict Minerals Disclosureand Report
ThisSpecialized 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 ExchangeAct of 1934, as amended ("Conflict Minerals Rule"), for the
calendar year ended December 31, 2023, and is posted on theCompany's website
at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-mineral
s
. Information containedon, 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 Item1.01 is filed as Exhibit 1.01 to
this Form SD.
Section 2 - Exhibits
Item 2.01 Exhibits
Exhibit Description
Number
1.01 Conflict Minerals Report for the calendar year ended December 31, 2023.
2
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 24, 2024 By: /s/ Kenneth A. Jacobson
Name: Kenneth A. Jacobson
Title: Chief Financial officer
3
Exhibit 1.01
CONFLICT MINERALS REPORT
For the Reporting Period from January 1to December 31, 2023
Introduction
ThisConflict Minerals Report of Avnet, Inc. for the calendar year 2023
("Report") is filed May 24, 2024, as an exhibitto the Company's Form SD, as
required under Rule 13p-1 of the Securities Exchange Act of 1934 (the
"Conflict MineralsRule"). The Report is posted on the Company's website at
https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals
.Other information available through the Company's website is not part of this
Report.
References to "the Company," "Avnet," "we," "our," or "us" means Avnet, Inc.
and its subsidiaries, except where the context otherwise requires.
Applicability of the Conflict Minerals Rule to Avnet
Avnetis as a global distributor of electronic components. It markets, sells,
and distributes electronic components from the world's leadingelectronic
component manufacturers, including semiconductors, IP&E components
(interconnect, passive and electromechanical),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 embeddedproducts, 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 discloseinformation
regarding any conflict minerals that are "necessary to the functionality or
production" of any product that itmanufactures or contracts to be
manufactured. The Securities and Exchange Commission ("SEC") defines conflict
minerals ascolumbite-tantalite (coltan), cassiterite, gold, wolframite, or
their derivatives, which are limited to tantalum, tin, and tungsten
(collectively, "CMs"). CMs are used in many electronic components and computer
products. The Democratic Republic of Congo and its adjoiningcountries have
extensive reserves of CMs, some of which are illegally sourced and traded by
armed groups who are responsible for significanthuman rights violations. The
purpose of the Conflict Minerals Rule is to encourage companies whose products
contain CMs to sourcefrom suppliers who do not directly or indirectly support
such armed groups through their purchasing decisions. The term CM refers to
thenamed minerals and their derivatives and does not imply that the
procurement of such minerals or derivatives directly or indirectly financedor
benefitted armed groups in the Democratic Republic of Congo or an adjoining
country.
Avnet's revenues for 2023 were largely from distribution andother services
that were not in-scope for purposes of compliance with the Conflict Minerals
Rule. However, during 2023, it manufacturedor contracted to manufacture
certain products that include CMs (collectively, "Covered Products").
Therefore, the Companyconducted a reasonable country of origin inquiry
("RCOI"), in good faith, to determine whether any of the CMs in the
CoveredProducts: (1) originated in the Democratic Republic of Congo or an
adjoining country, including Angola, Burundi, Central AfricanRepublic,
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.
The Company conducted further due diligence on the source and chainof custody
of such CMs that conformed, in all material respects, to an internationally
recognized due diligence framework as requiredby the Conflict Minerals Rule.
Please see "Conflict Minerals Program - Design of Conflict Minerals Program"
for moreinformation on the design of the due diligence program and "Conflict
Minerals Program - Due Diligence Efforts" for moreinformation on the due
diligence conducted.
1
Avnet is a downstream consumer of CMs. It does not purchase theCMs contained
in its Covered Products directly from mines, smelters, or refiners and is
generally many levels removed from such marketparticipants. Through the
efforts described in this Report, Avnet seeks to ensure that its sourcing
practices are consistent with itsResponsible 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 traceabilityof
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, including through its
engagement of Assent, a third-partyservice provider that is a member of RBA's
Responsible Minerals Initiative ("RMI"). In addition, the Company has
activelyengaged with its customers and suppliers for several years with
respect to the use of CMs. It has also adopted a Responsible MineralsSourcing
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 humanrights 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 supplychain.
Avnet supports the aims of the Responsible Business Alliance'sResponsible
Minerals Initiative (RMI) to identify, reduce and eventually eliminate the use
of conflict minerals that finance or benefitconflict or human rights
violations, and the Responsible Minerals Assurance Process (RMAP) to validate
responsible sources. Avnet encouragesits suppliers to likewise support such
efforts. "Conflict minerals" include tantalum, tin, tungsten and gold, which
are usedin many electronic components and computer products.
Under Section 1502 of the Dodd-Frank Wall Street Reformand Consumer Protection
Act and the U.S. Securities and Exchange Commission ("SEC") rules, Avnet is
required to annually reporton Form SD whether products it manufactures or
contracts to manufacture contain conflict minerals necessary to the
functionalityor 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 groupsthat 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 isa downstream consumer of
conflict minerals. It does not purchase directly from mines, smelters or
refiners and is many levels removedfrom such market participants. Avnet
endeavors to avoid purchasing products containing conflict minerals sourced
from CAHRAs that directlyor 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
Guidancefor Responsible Supply Chains of Minerals from Conflict-Affected and
High-Risk Areas
(OECD Framework). As a downstream consumer, Avnetexpects its suppliers to
provide proper verification of the country of origin and source of the
conflict minerals used in the productsthey supply to Avnet, utilizing the most
current Conflict Minerals Reporting Template (CMRT) developed by RMI. Avnet
also encourages itssuppliers to adopt similar policies, due diligence
frameworks, and management systems with respect to responsible minerals
sourcing todrive those efforts throughout their supply chain.
Thispolicy is available at https://www.avnet.com/wps/portal/us/about-avnet/human
-rights/conflict-minerals
.
2
Conflict Minerals Program
Design of Conflict Minerals Program
Avnet's 2023 Conflict Minerals Program ("2023 Program")utilized the
internationally recognized framework to identify the country of origin and
chain of custody of the CMs. The framework(which includes supplements for
gold, tin, tantalum, and tungsten) is called
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
("OECDFramework").
Avnet's supply chain with respect to the CMs in our Covered Productsis highly
complex. We do not purchase CMs directly from any mine, refiner, or smelter
and there are many parties in the supply chain betweenAvnet's direct supplier
and the mine from which the CM originated. Due to the Company's "downstream"
positionin the supply chain, it followed the principles outlined in the OECD
Framework for downstream companies with no direct relationships tosmelters or
refiners. Therefore, Avnet must rely, in good faith, on its direct suppliers
to provide information regarding the countryof origin and chain of custody of
the CMs included in the Covered Products and on third-party audit programs. It
is likely that yearsof engagement and propagation of expectations through many
tiers of the supply chain will be necessary before information returned
todownstream companies, such as Avnet, may be considered accurate and complete.
Covered Products
Avnet determined that the following products it manufactured or contractedto
manufacture in 2023 contained CMs necessary to the functionality or production
of those products:
. Semi-conductor electronic devices designed and contracted to be manufactured by Avnet per customer specifications.
. Electronic boards, electronic devices, display solutions, and Human-Machine Interface
(HMI) solutions manufactured or contracted to be manufactured by Avnet Embedded GmbH.
. Control boards and HMIs contracted to be manufactured.
. Server based products integrated from customer designed or off-the-shelf components by Avnet Integrated.
. Design kits and modules manufactured or contracted to be manufactured by Avnet.
. Development boards manufactured or contracted to be manufactured by EBV Elektronik.
. Development boards and accessories contracted to be manufactured by Avnet.
. Printed circuit board assembly (PCBA) designed by customer and contracted to be manufactured by Farnell.
. PCBA and high-level integration of customer products.
. Avnet Guardian products manufactured or contracted to be manufactured by Avnet.
. Cables and electromechanical assembled products manufactured or contracted to be manufactured by Avnet.
Pursuant to the Conflict Minerals Rule, Covered Products do not includeproducts
(i) that were not entered into the stream of commerce in 2023, and (ii) that
were manufactured or contracted to bemanufactured by entities that Avnet
acquired after April 2023.
Reasonable Country of Origin Inquiry
Pursuant to the Conflict Minerals Rule, Avnet conducted a RCOI on thesource
and chain of custody of CMs in its Covered Products to determine whether any
they originated in any of the Covered Countries andmay not have come from
recycled or scrap sources. To the extent applicable, Avnet conducted its RCOI
utilizing the same processes andprocedures that it established for conducting
its due diligence, in particular Steps 1 and 2 of the OECD Framework, which
are describedunder "Due Diligence Efforts" below.
3
The 2023 RCOI included 484 suppliers that Avnet identified as possiblyproviding
it with components, parts or products that contained CMs for its Covered
Products. These suppliers identified smelters and refinersthat may have
processed the CMs contained in the Covered Products. Such smelters and
refiners were compared against the Smelter Look-uptab of the Conflict Minerals
Reporting Template ("CMRT"), as well as the list of "conformant" smelters and
refinersand country of origin information published by the RBA's Responsible
Minerals Initiative ("RMI"), to validate the smeltersand refiners (validated
facilities are listed in
Appendix A
) and to determine the countries from where such validated facilitiesmay have
obtained CMs (countries are listed in
Appendix B)
. For this process, Avnet used the data its Suppliers provided on theirCMRTs
version 6.2 or higher along with RMI's due diligence of smelters and refiners
and audits under the Responsible Minerals AssuranceProcess ("RMAP") standard.
The RMAP uses an independent third-party audit of smelter and refiner
management systems and sourcingpractices to validate conformance with RMAP
protocols and current global standards.
The Company retained Assent, a third-party service provider, to assistin the
collection and review of supplier CMRTs and the identification of risks in the
supply chain. During the 2023 RCOI, Avnet contactedsuppliers via Assent
Sustainability Manager ("ASM"), a software-as-a-service platform that enables
users to manage and tracksupplier communications and allows suppliers to
upload completed CMRTs directly to the platform. ASM's functionality meets the
OECDFramework process expectations by evaluating the quality of each
supplier's response and assigning a health score based on the supplier'sdeclarat
ion of process engagement. Additionally, the results provided in this Report,
as well as the step-by-step process for supplierengagement and upstream due
diligence investigations performed, are managed through ASM.
Avnet requested that all suppliers complete a CMRT. On Avnet'sbehalf, Assent
offered training and educational resources to Suppliers to guide them on best
practices, completing a CMRT, and using theASM platform. Avnet monitored and
tracked all communications in ASM for future reporting and transparency. Avnet
may directly follow-upwith a supplier that does not respond after three
requests through ASM.
Supplier CMRTs undergo an automated data validation process to increasethe
completeness and accuracy of submissions and to identify any contradictory
answers. This data validation process is based on questionswithin the
declaration tab of the CMRT, which helps to identify areas that require
further classification or risk assessment, as wellas to understand the due
diligence efforts of the Suppliers. Data validation contributes to the health
assessment of Avnet's ConflictMinerals Program, and the results are shared
with suppliers regarding areas that require clarification or improvement.
Supplier CMRTs are accepted and classified as either valid or invalid.If a
supplier's CMRT is invalid, the supplier receives feedback and guidance on how
to correct the validation errors and is askedto submit a valid CMRT. In
addition, suppliers are provided training courses and direct engagement help
through Assent's multilingualSupplier Experience team.
Due Diligence Efforts
Basedon the findings of the 2023 RCOI, pursuant to the Conflict Minerals Rule,
Avnet conducted further due diligence on the source and chainof custody of
the CMs in its Covered Products. The Company designed its due diligence
measures toconform, in all material respects, with the
OECD Framework, which contains a five-step structure for due diligence.
1./////Establishstrong company management systems
. Avnet has a governance team and a working team to carry out its
Conflict Minerals Program. The governance team is made up of senior
management and 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 implementation of the program, diligence efforts, and
risk mitigation strategy. It also informs the governance team about
the results of the due diligence and risk mitigation efforts.
. Avnet uses 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 use of Assent and its software platform ASM. Avnet also leverages Assent's managed
services to work with dedicated program specialists who support Avnet's CM program and provide Avnet updates on program status.
. 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. This policy is reviewed annually by the governance team.
4
. Avnet's Global Supplier Quality Handbook further discloses its expectations for suppliers, including an
expectation that suppliers only source materials from environmentally and socially responsible suppliers.
. 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 uses 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 require their own suppliers to source CMs from responsible sources.
. By using 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./////Identifyand 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 substantial
majority 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. Avnet may directly follow-up with Suppliers
that do not respond after three requests through the ASM platform.
Follow-up with non-responsive suppliers continued into 2024.
. Supplier level risks include incomplete or invalid submitted CMRTs.
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. To the extent that
a CMRT is incomplete or 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 2024.
. Supplier level risks include weak or undeveloped Supplier CM programs. 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 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 used or is a
complete list of smelters and
refiners utilized for CMs
in the Covered Products.
5
. Supplier level risks include suppliers with problematic smelters and
refiners in its supply chain. The CMRT data validation process evaluates
responses for predetermined red flag indicators defined in the OECD Framework
to identify risks in the supply chain posed by smelters and refiners.
o 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.
o If a smelter's due diligence practices have not been audited against
the RMAP standard or the smelter is considered non-conformant by
RMAP, follow-ups may be conducted with Suppliers reporting those
facilities and the facilities are assessed for potential sourcing risks.
o The process uses multiple factors to determine the level of risk that each smelter and refiner poses
to the supply chain. Factors include: RMAP audit status, geographic proximity to Conflict-Affected
and High Risk Areas, known mineral source country of origin, credible evidence of unethical or
conflict sourcing, peer assessments conducted by credible third-party sources, and sanction risks.
3./////Designand 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." Feedback on Supplier CMRTs is given directly to suppliers
and educational resources are provided to assist suppliers in
corrective action methods or to improve their internal programs.
. Avnet works with Suppliers on an as-needed basis to assist them with
understanding the requirements of the Conflict Minerals Rule. Through Assent,
Avnet also offers training and educational resources to suppliers to guide
them on best practices, completing a CMRT, and using the ASM platform.
. 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.
. Working team leaders monitor risks and share the CM Program results, risk assessments,
and draft Form SD filings with the governance team to ensure transparency within Avnet.
. 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 and the Global Supplier
Quality Handbook also state 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 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.
. 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.
4./////Carryout independent third-party audit of supply chain due diligence
. Avnet is not positioned to conduct direct audits of smelters and refiners' due diligence
practices, as it is a downstream consumer of CMs and is generally many steps removed from
smelters and refiners that provide minerals and ores. Instead, it relies on initiatives such
as those led by RBA, including RMI, to conduct smelter and refinery due diligence audits.
5./////Reportannually 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.
6
Results of 2023 Conflict Minerals Program
As a downstream purchaser of components, parts and products that maycontain
CMs, Avnet's 2023 Program can provide only reasonable, but not absolute,
assurance regarding the country of origin and chainof custody of the necessary
CMs in its Covered Products.
The due diligence process includes Avnet requesting information fromits direct
suppliers, with those suppliers requesting similar information from their
suppliers and so on, up the supply chain, to eventuallyidentify the original
sources of the necessary CMs. However, those who purchase CMs directly from
smelters or refiners may not beable to discern which of its product lines
include specific CMs from each smelter or refiner, and so it is common
practice for such purchasersto list all smelters and refiners they may
purchase from within the reporting period. Likewise, suppliers' CMRTs
primarily providedinformation at the company level, with few at the product
level, and suppliers may have received similar information from their
suppliersand so on. Finally, not all suppliers completed CMRTs or completed
CMRTs in full for the 2023 Program.
For the 2023 Program, 484 Suppliers were identified, of which 333 (or68.8%)
submitted a completed CMRT, a decrease from the 2022 program.
Supplier CMRT Results
Year of # Suppliers in # Completed % Completed # Valid CMRTs % Valid CMRTs
Program Scope CMRTs CMRTs
2023 484 333 68.8 % 329 68.0 %
2022 429 297 69.2 % 290 67.6 %
Strength of Supplier CM Program Results
Year of # Completed # Suppliers with # Suppliers with Total Suppliers with % of such
Program CMRTS CM programs and no CMs in their strong CM Suppliers
policies rated as products programs/policies or no
strong CMs in products
2023 333 267 39 306 91.9 %
2022 297 228 37 265 89.2 %
The 351 legitimate smelters and refiners identified by Suppliers incompleted
CMRTs, which appear on the RMI-maintained smelters list, are listed in
Appendix A
. Based on the limitations explainedabove, this list may be incomplete or more
comprehensive than the smelters and refiners that actually processed the CMs
contained in theCovered Products. The below table summarizes the number of
such legitimate smelters and refiners that have been audited, are in the
processof being audited, or not enrolled to be audited by RMI utilizing the
RMAP standard as well as audit results.
Smelter and Refiner Audit Status Results
RMI Audit Status Legitimate Smelters and Refiners
RMAP Conformant 225 64.1 %
RMAP Active 6 1.7 %
Non-Conformant 29 8.3 %
Not Enrolled (roll up of the statuses below) 91 25.9 %
Total 351 100.00 %
7
Not Enrolled subcategories Count
Communication Suspended - Not Interested 6
Due Diligence Vetting Process 0
In Communication 1
Outreach Required 62
RMI Due Diligence Review - Unable to Proceed 22
The compliance status information provided inthe table above is based solely
on information made available by RMI, without independent verification by the
Company. Following are definitionsof certain terms used in the chart:
. "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.
. "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.
. "Non-Conformant" means that the smelter or refiner has been independently
assessed but found not to be in conformance with the relevant RMAP standard.
. "Communication Suspended - Not Interested" means the smelter or refiner has
strongly communicated a lack of interest in participating in the audit program.
. "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.
. "In Communication" means the smelter or refiner is not yet active but is in communications with RMAP and/or a member company.
. "Outreach Required" means RMI member companies need to contact entity to encourage their participation in audit program.
. "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 reportedsmelters and
refiners may have collectively sourced CMs, based on information provided
through the CMRT data collection process and RMAPaudits, is provided in
Appendix B
. Based on the limitations explained above, this list may be incomplete or
more comprehensivethan the list of countries from which CMs contained in the
Covered Products were actually sourced.
After conducting its 2023 Program, and in light of the limitationsexplained
above, Avnet concludes that it is unable to determine the origin of the CMs
contained in its Covered Products and unable todetermine whether its Covered
Products are DRC conflict free.
Steps to be taken in Calendar 2024
As Avnet endeavors not to purchase products that contain CMs that directlyor
indirectly finance or benefit armed groups in the Covered Countries, and to
mitigate the risk of purchasing such products, it has continuedwith its
Conflict Minerals Program discussed above during calendar year 2024 and
specifically plans to pursue the following steps andimprovements:
. Continue to engage with Suppliers that provided incomplete responses or no responses
for 2023 to help encourage them to provide requested information for 2024.
. Continue to encourage suppliers to improve their efforts and policies, particular with
suppliers whose conflict minerals compliance programs and policies are deemed weak.
8
. For new in-scope suppliers: (i) communicate Avnet's sourcing expectations, including through the dissemination of the
Responsible Minerals Sourcing Policy and Global Supplier Quality Handbook and inclusion of CM sourcing requirements
in supplier agreements; and (ii) 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 ASM 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 Actof 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-lookingstatements include
statements relating to the Company's future plans, additional steps it intends
to take to mitigate the risk thatthe 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 currentexpectations and
assumptions, which may not prove to be accurate. These statements are not
guarantees and are subject to risks, uncertaintiesand changes in circumstances
that are difficult to predict, including: (1) the continued implementation of
satisfactory traceabilityand 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 outcomesand
results may differ materially from these forward-looking statements. As a
result, these statements speak only as of the date theyare made and the
Company undertakes no obligation to update or revise any forward-looking
statement, except as required by federal securitieslaw.
9
APPENDIX A
List of Smelters and Refiners
Avnet utilized data its Suppliers provided on their CMRTs for the 2023Program
along with RBA's RMI due diligence of smelters and refiners to prepare the
below list. The list: (1) may not includeall smelters and refiners that
processed CMs in the Covered Products, and (2) may include smelters and
refiners that processed CMswhich were not contained in the products provided
by the Suppliers for the Covered Products.
For RMI Audit Status:
. "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.
. "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.
. "Non-Conformant" means that the smelter or refiner has been independently
assessed but found not to be in conformance with the relevant RMAP standard.
. "Communication Suspended - Not Interested" means the smelter or refiner has
strongly communicated a lack of interest in participating in the audit program.
. "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.
. "In Communication" means the smelter or refiner is not yet active but is in communications with RMAP and/or a member company.
. "Outreach Required" means RMI member companies need to contact entity to encourage their participation in audit program.
. "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 / Smelter / Refiner Name Smelter / Refiner RMI Audit Status
Refiner CID Location
Gold CID000015 Advanced Chemical Company United States Of America Active
Gold CID000019 Aida Chemical Industries Co., Ltd. Japan Conformant
Gold CID000035 Agosi AG 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
Gold 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
Gold CID000189 Cendres + Metaux S.A. Switzerland Non Conformant
10
Gold CID000197 Yunnan Copper China Outreach Required
Industry Co., Ltd.
Gold CID000233 Chimet S.p.A. Italy Conformant
Gold CID000264 Chugai Mining Japan Conformant
Gold CID000343 Daye Non-Ferrous China Outreach Required
Metals Mining Ltd.
Gold CID000359 DSC (Do Sung Corporation) Korea, Republic Of Conformant
Gold CID000401 Dowa Japan Conformant
Gold CID000425 Eco-System Recycling Japan Conformant
Co., Ltd. East Plant
Gold CID000493 JSC Novosibirsk Refinery Russian Federation RMI Due Diligence Review
- Unable to Proceed
Gold CID000522 Refinery of Seemine China Outreach Required
Gold Co., Ltd.
Gold CID000651 Guoda Safina High-Tech China Outreach Required
Environmental Refinery Co., Ltd.
Gold CID000671 Hangzhou Fuchunjiang China Outreach Required
Smelting Co., Ltd.
Gold CID000689 LT Metal Ltd. Korea, Republic Of Conformant
Gold CID000694 Heimerle + Meule GmbH Germany Conformant
Gold CID000707 Heraeus Metals China Conformant
Hong Kong Ltd.
Gold CID000711 Heraeus Germany Germany Conformant
GmbH Co. KG
Gold CID000767 Hunan Chenzhou China Outreach Required
Mining Co., Ltd.
Gold CID000773 Hunan Guiyang yinxing China Outreach Required
Nonferrous Smelting Co., Ltd.
Gold CID000778 HwaSeong CJ CO., LTD. Korea, Republic Of Communication Suspended
- Not Interested
Gold CID000801 Inner Mongolia Qiankun Gold and China Conformant
Silver Refinery Share Co., Ltd.
Gold CID000807 Ishifuku Metal Japan Conformant
Industry Co., Ltd.
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 Russian Federation RMI Due Diligence Review
Metal Processing Plant - Unable to Proceed
Gold CID000929 JSC Uralelectromed Russian Federation RMI Due Diligence Review
- Unable to Proceed
Gold CID000937 JX Nippon Mining & Japan Conformant
Metals Co., Ltd.
Gold CID000956 Kazakhmys Smelting LLC Kazakhstan Outreach Required
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
11
Gold CID001032 L'azurde Company Saudi Arabia RMI Due Diligence Review
For Jewelry - Unable to Proceed
Gold CID001056 Lingbao Gold Co., Ltd. China Outreach Required
Gold CID001058 Lingbao Jinyuan Tonghui China Outreach Required
Refinery Co., Ltd.
Gold CID001078 LS-NIKKO Copper Inc. Korea, Republic Of Conformant
Gold CID001093 Luoyang Zijin Yinhui China Outreach Required
Gold Refinery Co., Ltd.
Gold CID001113 Materion United States Of America Conformant
Gold CID001119 Matsuda Sangyo Co., Ltd. Japan Conformant
Gold CID001147 Metalor Technologies China Conformant
(Suzhou) Ltd.
Gold CID001149 Metalor Technologies China Conformant
(Hong Kong) Ltd.
Gold CID001152 Metalor Technologies Singapore Conformant
(Singapore) Pte., Ltd.
Gold CID001153 Metalor Technologies S.A. Switzerland Conformant
Gold CID001157 Metalor USA Refining United States Of America Conformant
Corporation
Gold CID001161 Metalurgica Met-Mex Mexico Conformant
Penoles S.A. De C.V.
Gold CID001188 Mitsubishi Materials Japan Conformant
Corporation
Gold CID001193 Mitsui Mining and Japan Conformant
Smelting Co., Ltd.
Gold CID001204 Moscow Special Alloys Russian Federation RMI Due Diligence Review
Processing Plant - Unable to Proceed
Gold CID001220 Nadir Metal Rafineri Turkey Conformant
San. Ve Tic. A.S.
Gold CID001236 Navoi Mining and Uzbekistan Conformant
Metallurgical Combinat
Gold CID001259 Nihon Material Co., Ltd. Japan Conformant
Gold CID001325 Ohura Precious Metal Japan Conformant
Industry Co., Ltd.
Gold CID001326 OJSC "The Gulidov Krasnoyarsk Non-Ferrous Russian Federation RMI Due Diligence Review
Metals Plant" (OJSC Krastsvetmet) - Unable to Proceed
Gold CID001352 MKS PAMP SA Switzerland Conformant
Gold CID001362 Penglai Penggang Gold China Outreach Required
Industry Co., Ltd.
Gold CID001386 Prioksky Plant of Russian Federation RMI Due Diligence Review
Non-Ferrous Metals - Unable to Proceed
Gold CID001397 PT Aneka Tambang Indonesia Conformant
(Persero) Tbk
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 Non Conformant
Gold CID001562 Samwon Metals Corp. Korea, Republic Of Communication Suspended
- Not Interested
Gold CID001585 SEMPSA Joyeria Spain Conformant
Plateria S.A.
Gold CID001619 Shandong Tiancheng Biological China Outreach Required
Gold Industrial Co., Ltd.
12
Gold CID001622 Shandong Zhaojin Gold & China Conformant
Silver Refinery Co., Ltd.
Gold CID001736 Sichuan Tianze Precious China Conformant
Metals Co., Ltd.
Gold CID001756 SOE Shyolkovsky Factory of Russian Federation RMI Due Diligence Review
Secondary Precious Metals - Unable to Proceed
Gold CID001761 Solar Applied Materials Taiwan, Province Of China Conformant
Technology Corp.
Gold CID001798 Sumitomo Metal Japan Conformant
Mining Co., Ltd.
Gold CID001810 Super Dragon Taiwan, Province Of China Outreach Required
Technology Co., Ltd.
Gold CID001875 Tanaka Kikinzoku Japan Conformant
Kogyo K.K.
Gold CID001909 Great Wall Precious China Outreach Required
Metals Co., Ltd. of CBPM
Gold CID001916 Shandong Gold China Conformant
Smelting Co., Ltd.
Gold CID001938 Tokuriki Honten Co., Ltd. Japan Conformant
Gold CID001947 Tongling Nonferrous China Outreach Required
Metals Group Co., Ltd.
Gold CID001955 Torecom Korea, Republic Of Conformant
Gold CID001980 Umicore S.A. Business Unit Belgium Conformant
Precious Metals Refining
Gold CID001993 United Precious Metal United States Of America Conformant
Refining, Inc.
Gold CID002003 Valcambi S.A. Switzerland Conformant
Gold CID002030 Western Australian Mint Australia Conformant
(T/a The Perth Mint)
Gold CID002100 Yamakin Co., Ltd. Japan Conformant
Gold CID002129 Yokohama Metal Co., Ltd. Japan Conformant
Gold CID002224 Zhongyuan Gold Smelter of China Conformant
Zhongjin Gold Corporation
Gold CID002243 Gold Refinery of Zijin China Conformant
Mining Group Co., Ltd.
Gold CID002282 Morris and Watson New Zealand Outreach Required
Gold CID002290 SAFINA A.S. Czechia Conformant
Gold CID002312 Guangdong Jinding China Outreach Required
Gold Limited
Gold CID002314 Umicore Precious Thailand Non Conformant
Metals Thailand
Gold CID002509 MMTC-PAMP India Pvt., Ltd. India Conformant
Gold CID002511 KGHM Polska Miedz Poland Conformant
Spolka Akcyjna
Gold CID002515 Fidelity Printers Zimbabwe RMI Due Diligence Review
and Refiners Ltd. - Unable to Proceed
Gold CID002516 Singway Technology Taiwan, Province Of China Non Conformant
Co., Ltd.
Gold CID002525 Shandong Humon China Outreach Required
Smelting Co., Ltd.
Gold CID002527 Shenzhen Zhonghenglong China Outreach Required
Real Industry Co., Ltd.
Gold CID002560 Al Etihad Gold United Arab Emirates Non Conformant
Refinery DMCC
Gold CID002561 Emirates Gold DMCC United Arab Emirates Non Conformant
Gold CID002562 International Precious United Arab Emirates Outreach Required
Metal Refiners
13
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
Gold CID002587 Industrial Belgium Non Conformant
Refining Company
Gold CID002588 Shirpur Gold Refinery Ltd. India Outreach Required
Gold CID002605 Korea Zinc Co., Ltd. Korea, Republic Of Conformant
Gold CID002606 Marsam Metals Brazil Non Conformant
Gold CID002615 TOO Tau-Ken-Altyn Kazakhstan Conformant
Gold CID002708 Abington Reldan United States Of America Conformant
Metals, LLC
Gold CID002750 Shenzhen CuiLu China Outreach Required
Gold Co., Ltd.
Gold CID002760 Albino Mountinho Lda. Portugal Outreach Required
Gold CID002761 SAAMP France Non Conformant
Gold CID002762 L'Orfebre S.A. Andorra Conformant
Gold CID002763 8853 S.p.A. Italy Non Conformant
Gold CID002765 Italpreziosi Italy Conformant
Gold CID002778 WIELAND Edelmetalle GmbH Germany Conformant
Gold CID002779 Ogussa Osterreichische Gold- Austria Conformant
und Silber-Scheideanstalt GmbH
Gold CID002850 AU Traders and Refiners South Africa Non Conformant
Gold CID002852 GGC Gujrat Gold India Non Conformant
Centre Pvt. Ltd.
Gold CID002853 Sai Refinery India Outreach Required
Gold CID002857 Modeltech Sdn Bhd Malaysia Non Conformant
Gold CID002863 Bangalore Refinery India Active
Gold CID002865 Kyshtym Copper-Electrolytic Russian Federation RMI Due Diligence Review
Plant ZAO - Unable to Proceed
Gold CID002867 Degussa Sonne / Mond Germany Outreach Required
Goldhandel GmbH
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 Chile Conformant
de Metales SpA
Gold CID002920 ABC Refinery Pty Ltd. Australia Outreach Required
Gold CID002973 Safimet S.p.A Italy Non Conformant
Gold CID003153 State Research Institute Center for Lithuania Outreach Required
Physical Sciences and Technology
Gold CID003185 African Gold Refinery Uganda RMI Due Diligence Review
- Unable to Proceed
Gold CID003186 Gold Coast Refinery Ghana Outreach Required
14
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 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 Non Conformant
Gold CID003463 Kundan Care Products Ltd. India Outreach Required
Gold CID003487 Emerald Jewel Industry India Limited (Unit 1) India Outreach Required
Gold CID003488 Emerald Jewel Industry India Limited (Unit 2) India Outreach Required
Gold CID003489 Emerald Jewel Industry India Limited (Unit 3) India Outreach Required
Gold CID003490 Emerald Jewel Industry India Limited (Unit 4) India Outreach Required
Gold CID003497 K.A. Rasmussen Norway Outreach Required
Gold CID003500 Alexy Metals United States Of America Non Conformant
Gold CID003548 MD Overseas India Outreach Required
Gold CID003557 Metallix Refining Inc. United States Of America Outreach Required
Gold CID003575 Metal Concentrators SA (Pty) Ltd. South Africa Conformant
Gold CID003615 WEEEREFINING France Conformant
Gold CID003641 Gold by Gold Colombia Colombia Conformant
Gold CID003663 Dongwu Gold Group China Outreach Required
Gold CID003666 Sam Precious Metals United Arab Emirates Outreach Required
Gold CID004010 Coimpa Industrial LTDA Brazil Conformant
Gold CID004506 GG Refinery Ltd. Tanzania, United Republic Of Active
Gold CID004697 Attero Recycling Pvt Ltd Outreach Required
Tantalum CID000460 F&X Electro-Materials Ltd. China Conformant
Tantalum CID000616 XIMEI RESOURCES (GUANGDONG) LIMITED China Conformant
Tantalum CID000914 JiuJiang JinXin Nonferrous Metals Co., Ltd. China Conformant
Tantalum CID000917 Jiujiang Tanbre Co., Ltd. China Conformant
Tantalum CID001076 AMG Brasil 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
15
Tantalum CID001769 Solikamsk Magnesium Russian Federation RMI Due Diligence Review
Works OAO - Unable to Proceed
Tantalum CID001869 Taki Chemical Co., Ltd. Japan Conformant
Tantalum CID001891 Telex Metals United States Of America Conformant
Tantalum CID001969 Ulba Metallurgical Kazakhstan Conformant
Plant JSC
Tantalum CID002492 Hengyang King Xing Lifeng China Conformant
New Materials Co., Ltd.
Tantalum CID002504 D Block Metals, LLC United States Of America Conformant
Tantalum CID002505 FIR Metals & Resource Ltd. China Conformant
Tantalum CID002506 Jiujiang Zhongao Tantalum China Conformant
& Niobium Co., Ltd.
Tantalum CID002508 XinXing HaoRong Electronic China Conformant
Material Co., Ltd.
Tantalum CID002512 Jiangxi Dinghai Tantalum China Conformant
& Niobium Co., Ltd.
Tantalum CID002539 KEMET de Mexico Mexico Conformant
Tantalum CID002544 TANIOBIS Co., Ltd. Thailand Conformant
Tantalum CID002545 TANIOBIS GmbH Germany Conformant
Tantalum CID002548 Materion Newton Inc. United States Of America Conformant
Tantalum CID002549 TANIOBIS Japan Co., Ltd. Japan Conformant
Tantalum CID002550 TANIOBIS Smelting Germany Conformant
GmbH & Co. KG
Tantalum CID002557 Global Advanced United States Of America Conformant
Metals Boyertown
Tantalum CID002558 Global Advanced Japan Conformant
Metals Aizu
Tantalum CID002707 Resind Industria Brazil Conformant
e Comercio Ltda.
Tantalum CID002842 Jiangxi Tuohong China Conformant
New Raw Material
Tantalum CID003583 RFH Yancheng Jinye New China Conformant
Material Technology Co., Ltd.
Tantalum CID003926 5D Production OU Estonia Outreach Required
Tantalum CID000291 Guangdong Rising Rare China Conformant
Metals-EO Materials Ltd.
Tantalum CID004054 PowerX Ltd. Rwanda Conformant
Tin CID000228 Chenzhou Yunxiang Mining China Conformant
and Metallurgy Co., Ltd.
Tin CID000292 Alpha United States Of America Conformant
Tin CID000309 PT Aries Kencana Sejahtera Indonesia Conformant
Tin CID000313 PT Premium Tin Indonesia Indonesia Conformant
Tin CID000402 Dowa Japan Conformant
Tin CID000438 EM Vinto Bolivia (Plurinational Conformant
State Of)
Tin CID000448 Estanho de Rondonia S.A. Brazil Conformant
Tin CID000468 Fenix Metals Poland Conformant
Tin CID000538 Gejiu Non-Ferrous Metal China Conformant
Processing Co., Ltd.
Tin CID000555 Gejiu Zili Mining And China Non Conformant
Metallurgy Co., Ltd.
16
Tin CID000942 Gejiu Kai Meng China Non Conformant
Industry and Trade LLC
Tin CID001070 China Tin Group Co., Ltd. China Conformant
Tin CID001105 Malaysia Smelting Malaysia Conformant
Corporation (MSC)
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 Japan Conformant
Corporation
Tin CID001231 Jiangxi New Nanshan China Conformant
Technology Ltd.
Tin CID001305 Novosibirsk Tin Combine Russian Federation RMI Due Diligence Review
- Unable to Proceed
Tin CID001314 O.M. Manufacturing Thailand Conformant
(Thailand) Co., Ltd.
Tin CID001337 Operaciones Bolivia (Plurinational Conformant
Metalurgicas S.A. State Of)
Tin CID001399 PT Artha Cipta Langgeng Indonesia Conformant
Tin CID001402 PT Babel Inti Perkasa Indonesia Conformant
Tin CID001406 PT Babel Surya Indonesia Conformant
Alam Lestari
Tin CID001419 PT Bangka Tin Industry Indonesia Active
Tin CID001421 PT Belitung Indonesia Conformant
Industri Sejahtera
Tin CID001428 PT Bukit Timah Indonesia Conformant
Tin CID001453 PT Mitra Stania Prima Indonesia Conformant
Tin CID001457 PT Panca Mega Persada Indonesia Outreach Required
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 Conformant
Tin CID001490 PT Tinindo Inter Nusa Indonesia Conformant
Tin CID001493 PT Tommy Utama Indonesia Conformant
Tin CID001539 Rui Da Hung Taiwan, Province Of China Conformant
Tin CID001898 Thaisarco Thailand Conformant
Tin CID001908 Gejiu Yunxin Nonferrous China Non Conformant
Electrolysis Co., Ltd.
Tin CID002015 VQB Mineral and Viet Nam Outreach Required
Trading Group JSC
Tin CID002036 White Solder Metalurgia Brazil Conformant
e Mineracao Ltda.
Tin CID002158 Yunnan Chengfeng Non-ferrous China Conformant
Metals Co., Ltd.
Tin CID002180 Tin Smelting Branch of China Conformant
Yunnan Tin Co., Ltd.
Tin CID002455 CV Venus Inti Perkasa Indonesia Conformant
Tin CID002468 Magnu's Minerais Brazil Conformant
Metais e Ligas Ltda.
17
Tin CID002478 PT Tirus Putra Mandiri Indonesia Communication Suspended
- Not Interested
Tin CID002500 Melt Metais e Ligas S.A. Brazil Non Conformant
Tin CID002503 PT ATD Makmur Mandiri Jaya Indonesia Conformant
Tin CID002517 O.M. Manufacturing Philippines Conformant
Philippines, Inc.
Tin CID002570 CV Ayi Jaya Indonesia Conformant
Tin CID002572 Electro-Mechanical Facility of the Cao Bang Viet Nam Non Conformant
Minerals & Metallurgy Joint Stock Company
Tin CID002573 Nghe Tinh Non-Ferrous Viet Nam Outreach Required
Metals Joint Stock Company
Tin CID002574 Tuyen Quang Non-Ferrous Viet Nam Outreach Required
Metals Joint Stock Company
Tin CID002593 PT Rajehan Ariq Indonesia Conformant
Tin CID002696 PT Cipta Persada Mulia Indonesia Conformant
Tin CID002703 An Vinh Joint Stock Mineral Viet Nam Outreach Required
Processing Company
Tin CID002706 Resind Industria Brazil Conformant
e Comercio Ltda.
Tin CID002756 Super Ligas Brazil Conformant
Tin CID002773 Aurubis Beerse Belgium Conformant
Tin CID002774 Aurubis Berango Spain Conformant
Tin CID002776 PT Bangka Prima Tin Indonesia Conformant
Tin CID002816 PT Sukses Inti Makmur Indonesia Conformant
Tin CID002835 PT Menara Cipta Mulia Indonesia Conformant
Tin CID002858 Modeltech Sdn Bhd Malaysia Non Conformant
Tin CID003116 Guangdong Hanhe Non-Ferrous China Conformant
Metal Co., Ltd.
Tin CID003190 Chifeng Dajingzi Tin China Conformant
Industry Co., Ltd.
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 China Non Conformant
Engineering Co., Ltd.
Tin CID003381 PT Rajawali Rimba Perkasa Indonesia Conformant
Tin CID003387 Luna Smelter, Ltd. Rwanda Conformant
Tin CID003397 Yunnan Yunfan Non-ferrous China Conformant
Metals Co., Ltd.
Tin CID003409 Precious Minerals and India Active
Smelting Limited
Tin CID003410 Gejiu City Fuxiang Industry China Outreach Required
and Trade Co., Ltd.
Tin CID003449 PT Mitra Sukses Globalindo Indonesia Conformant
Tin CID003486 CRM Fundicao De Metais E Comercio De Brazil Conformant
Equipamentos Eletronicos Do Brasil Ltda
Tin CID003524 CRM Synergies Spain Conformant
Tin CID003582 Fabrica Auricchio Industria Brazil Conformant
e Comercio Ltda.
Tin CID003831 DS Myanmar Myanmar Conformant
Tin CID003868 PT Putera Sarana Indonesia Conformant
Shakti (PT PSS)
18
Tin CID002844 HuiChang Hill Tin China Conformant
Industry Co., Ltd.
Tin CID003379 Ma'anshan Weitai China Non Conformant
Tin Co., Ltd.
Tin CID004065 Mining Minerals Congo, Democratic Conformant
Resources SARL Republic Of The
Tin CID004434 Malaysia Smelting Corporation Malaysia In Communication
Berhad (Port Klang)
Tungsten CID000004 A.L.M.T. Corp. Japan Conformant
Tungsten CID000105 Kennametal Huntsville United States Of America Conformant
Tungsten CID000218 Guangdong Xianglu China Conformant
Tungsten Co., Ltd.
Tungsten CID000258 Chongyi Zhangyuan China Conformant
Tungsten Co., Ltd.
Tungsten CID000281 CNMC (Guangxi) China Outreach Required
PGMA Co., Ltd.
Tungsten CID000568 Global Tungsten United States Of America Conformant
& Powders LLC
Tungsten CID000766 Hunan Chenzhou China Conformant
Mining Co., Ltd.
Tungsten CID000769 Hunan Jintai New China Non Conformant
Material Co., Ltd.
Tungsten CID000825 Japan New Metals Co., Ltd. Japan Conformant
Tungsten CID000966 Kennametal Fallon United States Of America Conformant
Tungsten CID002044 Wolfram Bergbau Austria Conformant
und Hutten AG
Tungsten CID002082 Xiamen Tungsten Co., Ltd. China Conformant
Tungsten CID002313 Jiangxi Minmetals Gao'an China Communication Suspended
Non-ferrous Metals Co., Ltd. - Not Interested
Tungsten CID002315 Ganzhou Jiangwu China Conformant
Ferrotungsten Co., Ltd.
Tungsten CID002316 Jiangxi Yaosheng China Conformant
Tungsten Co., Ltd.
Tungsten CID002317 Jiangxi Xinsheng Tungsten China Conformant
Industry Co., Ltd.
Tungsten CID002318 Jiangxi Tonggu Non-ferrous China Conformant
Metallurgical & Chemical Co., Ltd.
Tungsten CID002319 Malipo Haiyu China Conformant
Tungsten Co., Ltd.
Tungsten CID002320 Xiamen Tungsten China Conformant
(H.C.) Co., Ltd.
Tungsten CID002321 Jiangxi Gan Bei China Conformant
Tungsten Co., Ltd.
Tungsten CID002494 Ganzhou Seadragon China Conformant
W & Mo Co., Ltd.
Tungsten CID002502 Asia Tungsten Viet Nam Conformant
Products Vietnam Ltd.
Tungsten CID002513 Hunan Shizhuyuan Nonferrous Metals Co., China Conformant
Ltd. Chenzhou Tungsten Products Branch
Tungsten CID002541 H.C. Starck Tungsten GmbH Germany Conformant
Tungsten CID002542 TANIOBIS Smelting Germany Conformant
GmbH & Co. KG
Tungsten CID002543 Masan High-Tech Materials Viet Nam Conformant
Tungsten CID002551 Jiangwu H.C. Starck China Conformant
Tungsten Products Co., Ltd.
Tungsten CID002589 Niagara Refining LLC United States Of America Conformant
Tungsten CID002641 China Molybdenum China Conformant
Tungsten Co., Ltd.
Tungsten CID002649 Hydrometallurg, JSC Russian Federation RMI Due Diligence Review
- Unable to Proceed
Tungsten CID002724 Unecha Refractory Russian Federation Non Conformant
metals plant
19
Tungsten CID002827 Philippine Chuangxin Philippines Conformant
Industrial Co., Inc.
Tungsten CID002833 ACL Metais Eireli Brazil Non Conformant
Tungsten CID002845 Moliren Ltd. Russian Federation RMI Due Diligence Review
- Unable to Proceed
Tungsten CID003407 Lianyou Metals Co., Ltd. Taiwan, Province Of China Conformant
Tungsten CID003408 JSC "Kirovgrad Russian Federation RMI Due Diligence Review
Hard Alloys Plant" - Unable to Proceed
Tungsten CID003416 NPP Tyazhmetprom LLC Russian Federation RMI Due Diligence Review
- Unable to Proceed
Tungsten CID003417 Hubei Green China Conformant
Tungsten Co., Ltd.
Tungsten CID003427 Albasteel Industria e Comercio Brazil Non Conformant
de Ligas Para Fundicao Ltd.
Tungsten CID003468 Cronimet Brasil Ltda Brazil Conformant
Tungsten CID003553 Artek LLC Russian Federation RMI Due Diligence Review
- Unable to Proceed
Tungsten CID003609 Fujian Xinlu China Conformant
Tungsten Co., Ltd.
Tungsten CID003612 OOO "Technolom" 2 Russian Federation RMI Due Diligence Review
- Unable to Proceed
Tungsten CID003614 OOO "Technolom" 1 Russian Federation RMI Due Diligence Review
- Unable to Proceed
Tungsten CID003643 LLC Vostok Russian Federation RMI Due Diligence Review
- Unable to Proceed
Tungsten CID003662 YUDU ANSHENG China Outreach Required
TUNGSTEN CO., LTD.
Tungsten CID003978 HANNAE FOR T Co., Ltd. Korea, Republic Of Outreach Required
Tungsten CID003993 Tungsten Vietnam Viet Nam Conformant
Joint Stock Company
Tungsten CID004060 DONGKUK INDUSTRIES Korea, Republic Of Outreach Required
CO., LTD.
Tungsten CID004034 Nam Viet Cromit Viet Nam Outreach Required
Joint Stock Company
Tungsten CID004397 Lianyou Resources Taiwan, Province Of China Conformant
Co., Ltd.
Tungsten CID004430 Shinwon Tungsten (Fujian China Conformant
Shanghang) Co., Ltd.
Tungsten CID004619 Kenee Mining Viet Nam Active
Corporation Vietnam
20
APPENDIX B
Countries of Origin
Avnet utilized data its suppliers provided on their CMRTs for the 2023Program
and relied on information provided by RBA's RMI due diligence of smelters and
refiners regarding the countries of originand mines or locations of origin to
prepare the below list. The list: (1) may not include all countries that
ultimately sourced theCMs in the Covered Products, and (2) may include
countries that did not ultimately source CMs contained in the Covered Products.
Country of Origin (Material)
Albania Ecuador Kyrgyzstan Saudi Arabia
Andorra Egypt Liberia Senegal
Angola El Salvador Liechtenstein Serbia
Argentina Eritrea Lithuania Sierra Leone
Armenia Estonia Luxembourg Singapore
Australia Ethiopia Madagascar Slovakia
Austria Fiji Malaysia South Africa
Azerbaijan Finland Mali South Sudan
Belarus France Mauritania Spain
Belgium Georgia Mexico Sudan
Benin Germany Mongolia Suriname
Bermuda Ghana Morocco Sweden
Bolivia (Plurinational State of) Guam Mozambique Switzerland
Botswana Guatemala Myanmar Taiwan
Brazil Guinea Namibia Tajikistan
Bulgaria Guyana Netherlands Tanzania
Burkina Faso Honduras New Zealand Thailand
Burundi Hong Kong Nicaragua Togo
Cambodia Hungary Niger Turkey
Canada India Nigeria Uganda
Central African Republic Indonesia Norway United Arab Emirates
Chile Ireland Oman United Kingdom
China Israel Panama United States of America
Colombia Italy Papua New Guinea Uruguay
Congo Ivory Coast Peru Uzbekistan
Cyprus Japan Philippines VietNam
Democratic Republic of Congo Jersey Poland Zambia
Djibouti Kazakhstan Portugal
Dominica Kenya Russian Federation
Dominican Republic Korea Rwanda
21
{graphic omitted}