UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
QUALYS, INC.
(Exact name of registrant as specified in its charter)
| Delaware | 001-35662 | 77-0534145 | ||
| (State or other jurisdiction of incorporation or organization) |
(Commission File Number) |
(IRS Employer Identification No.) |
919 E. Hillsdale Boulevard, 4th Floor, Foster City, California 94404
(Address of principal executive offices) (Zip Code)
Bruce K. Posey, Vice President, General Counsel and Corporate Secretary
(650) 801-6100
(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:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
With respect to the reporting period from January 1, 2017 to December 31, 2017, Qualys, Inc. (“Qualys” or the “Company”) evaluated its current products and determined that certain products it manufactures, or causes to be manufactured, contain gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives (“Conflict Minerals”). Following this initial determination, the Company conducted a reasonable country of origin inquiry and additional due diligence designed to conform with the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, including the related supplements on gold, tin, tantalum and tungsten (the “Framework”), in order to determine whether the Conflict Minerals contained in the Company’s products originated from the Democratic Republic of Congo, the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia or Angola (collectively, the “Covered Countries”).
Based on these due diligence efforts, the Company has reason to believe that certain Conflict Minerals contained in its products may have originated in the Covered Countries and may not be Conflict Minerals from recycled or scrap sources. However, the Company does not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals contained in its products or whether such Conflict Minerals are from recycled or scrap sources. The Company conducted due diligence on the source and chain of custody of these Conflict Minerals and prepared the Conflict Minerals Report attached hereto as Exhibit 1.01.
Conflict Minerals Disclosure
This Form SD of Qualys is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2017 to December 31, 2017.
A copy of Qualys’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD, and is publicly available at http://investor.qualys.com/sec.cfm.
Item 1.02 Exhibit
As specified in Section 2, Item 2.01 of this Form SD, Qualys is hereby filing its Conflict Minerals Report as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits.
Exhibit 1.01 – 2017 Conflict Minerals Report of Qualys, Inc. as required by Items 1.01 and 1.02 of this Form SD.
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| Qualys, Inc. | ||
| By: | /s/ Bruce K. Posey | |
| Name: | Bruce K. Posey | |
| Title: | Vice President, General Counsel and Corporate Secretary | |
Date: May 25, 2018
Exhibit 1.01
Qualys, Inc.
Conflict Minerals Report
For The Reporting Period from January 1, 2017 to December 31, 2017
This Conflict Minerals Report (this “Report”) of Qualys, Inc. (“we,” “Qualys” or the “Company”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2017 to December 31, 2017 (the “Reporting Period”).
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products where the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals are referred to as “Conflict Minerals,” which include gold, columbite-tantalite (coltan), cassiterite, wolframite and their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for purposes of the Rule and this Report are the Democratic Republic of Congo (the “DRC”), the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Company Overview
We are a pioneer and leading provider of a cloud-based platform delivering security and compliance solutions that enable organizations to identify security risks to their information technology (IT) infrastructures, help protect their IT systems and applications from ever-evolving cyber-attacks and achieve compliance with internal policies and external regulations. Our cloud solutions address the growing security and compliance complexities and risks that are amplified by the dissolving boundaries between internal and external IT infrastructures and web environments, the rapid adoption of cloud computing and the proliferation of geographically dispersed IT assets. Our integrated suite of security and compliance solutions delivered on our Qualys cloud platform enables our customers to identify their IT assets, collect and analyze large amounts of IT security data, discover and prioritize vulnerabilities, recommend remediation actions and verify the implementation of such actions. Organizations use our integrated suite of solutions delivered on our Qualys cloud platform to cost-effectively obtain a unified view of their security and compliance posture across globally-distributed IT infrastructures as our solution offers a single platform for information security, application security, endpoint, developer security and cloud teams.
Our cloud platform utilizes sensors, including physical, virtual and cloud scanners, and cloud agents that provide our customers with continuous visibility enabling customers to respond to threats immediately. It automatically gathers and analyzes security and compliance data in a scalable, state-of-the-art backend. The technology underlying our cloud infrastructure enables us to ingest, process, analyze and store a high volume of sensor data coming from our agents, scanners and passive analyzers, and correlate information at very high speeds in a distributed manner for millions of devices.
Description of the Company’s Products Covered by this Report
This Report relates to our managed scanner appliances: (i) for which Conflict Minerals are necessary to their functionality or production, (ii) that were manufactured, or contracted to be manufactured, by the Company, and (iii) for which the manufacture was completed during the Reporting Period. In this Report, we refer to these products collectively as the “Covered Products.”
Description of the Company’s Reasonable Country of Origin Inquiry
We have determined that Conflict Minerals are necessary to the functionality or production of the Covered Products that were manufactured or contracted to be manufactured by us during the Reporting Period. As a result, we conducted in good faith a reasonable country of origin inquiry (“RCOI”) reasonably designed to determine if any of these Conflict Minerals originated in the Covered Countries and whether any of the Conflict Minerals may be from recycled or scrap sources.
Our supply chain is complex, and there are many third parties in the supply chain between the ultimate manufacturer of the Covered Products and the original sources of Conflict Minerals. We do not directly purchase Conflict Minerals from mines, smelters or refiners. Therefore, we must rely on our contract manufacturers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products. In designing our RCOI, we determined to survey all of our first tier contract manufacturers.
As such, our RCOI primarily consisted of requesting the Conflict-Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template (“CMRT”) be completed and returned to us from our first tier contract manufacturers. Responses were reviewed for completeness, reasonableness, and consistency, and we followed up with our contract manufacturers for corrections and clarifications as needed.
We requested from our eight contract manufacturers that they complete the CMRT, and we received a 100% response rate. One manufacturer reported that it did not source from the Covered Countries. Based on the smelter lists provided by our suppliers via the CMRTs, an aggregate of 322 facilities or smelters were used by our contract manufacturers to fulfill their requirements for Conflict Minerals. Of these 322 facilities and smelters, we have identified 252 facilities or smelters that are deemed to be compliant with the Conflict-Free Smelter Program (“CFSP”). There are seven more smelters or refiners that are deemed “active” by the CFSP, which means such smelters or refiners have committed to undergo a CFSP audit or are participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. The remaining 63 facilities or smelters identified by our contract manufacturers are not on the CFSI lists for compliant or active smelters. We have assessed these 63 facilities and determined that most of these are of low risk due to their geographic location. There are four smelters or refiners that may be considered at greater risk because they are geographically located in Africa. However, there is no guarantee that these 63 facilities or smelters are present in our supply chain as our contract manufacturers were only able to provide company-level CMRTs, rather than product-level CMRTs directly linking smelters or refiners to the Covered Products.
Based on these due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals contained in the Covered Products or whether the Conflict Minerals in the Covered Products are from recycled or scrap sources.
Description of the Company’s Due Diligence Process
Based on the information provided by our contract manufacturers, we performed additional due diligence on the source and chain of custody of these Conflict Minerals which was designed to conform to 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, including the related supplements on gold, tin, tantalum and tungsten (the “Framework”), in order to determine if any Conflict Minerals included in our Covered Products may have originated in the Covered Countries and if so, whether they benefited armed groups in those countries.
After performing the RCOI and due diligence designed to conform with the Framework, we were unable to comprehensively establish the origin of all Conflict Minerals used in our Covered Products, the facilities used to process them, their country of origin, and their mine or location of origin.
In accordance with the five-step Framework, the design of our due diligence includes the following five steps: (i) establishment of strong company management systems, (ii) identification and assessment of risks in the supply chain, (iii) designing and implementing a strategy to respond to identified risks, (iv) carrying out independent third-party audit of smelter’s/refiner’s due diligence practices, and (v) reporting on supply chain due diligence. A description of certain activities undertaken by us with respect to each of the five steps of the Framework is described below.
| 1. | Establishment of Strong Company Management Systems |
We have completed a number of steps to establish a management system for addressing the sourcing of Conflict Minerals in our Covered Products. These actions include:
| a. | Adopt and Commit to a Supply Chain Policy for Conflict Minerals: We are committed to sourcing minerals for our products in a manner that does not finance or benefit armed groups in the Covered Countries. We have a Code of Business Conduct and Ethics (“Code of Conduct”) available at http://investor.qualys.com/corporate-governance.cfm which requires honest and ethical conduct and compliance with all applicable laws. Our Code of Conduct provides that we select suppliers not only on the merits of their products and services, but also on their business practices and that we will not establish business relationships with any suppliers if we know or have reason to believe that their business practices violate any applicable laws. Information contained on, or that can be accessed through, our website, does not constitute part of this Report and inclusion of our website address in this Report is an inactive textual reference only. |
| b. | Internal Management to Support Supply Chain Due Diligence: Our management has established an internal compliance team which includes members from our operations, legal and finance departments, charged with the development and implementation of our Conflict Minerals Program. |
| c. | Controls and Transparency to Support Supply Chain Diligence: As described above, we undertook a RCOI with respect to the Conflict Minerals in our supply chain by requesting the CMRT be completed by each of our contract manufacturers to gather information about their use of Conflict Minerals, the smelters and refiners in their supply chain that are included in our Covered Products, and the countries of origin for such Conflict Minerals. |
| d. | Supplier Engagement: We continue to actively engage with our contract manufacturers to strengthen our relationship with them. We have communicated to our contract manufacturers our commitment to sourcing Conflict Minerals in a manner that does not benefit armed groups in the Covered Countries. Further, we will continue to engage with our suppliers and encourage them to provide responses at a product level so that we can fully assess our supply chain. |
Lastly, we have communicated to our contract vendors who have listed facilities or smelters which have an indeterminable status, that we are evaluating their responses and may elect to seek alternative arrangements with other contract manufacturers. We expect to continue our efforts to ensure that the minerals in our products do not originate from the Covered Countries and do not directly or indirectly finance armed conflict or benefit armed groups.
| e. | Grievance Mechanism: Our Code of Conduct includes procedures for reporting violations of our Code of Conduct, including how to report such violations anonymously. We believe that this is an appropriate mechanism for our employees to report violations of our Code of Conduct. |
| 2. | Identification and Assessment of Risks in the Supply Chain |
Because of our position within our supply chain, it is difficult for us to identify actors upstream from our first tier contract manufacturers. As discussed above, we identified eight first tier contract manufacturers and we have relied upon them to provide us with the necessary information about the source of Conflict Minerals contained in the products that we contract with them to manufacture for us. Our contract manufacturers are similarly reliant upon information provided by their suppliers to provide information regarding the country of origin of Conflict Minerals that are included in the Covered Products.
| 3. | Designing and Implementing a Strategy to Respond to Identified Risks |
We address any risks identified through the process described in Step 2 above on a case-by-case basis. During the Reporting Period, when our contract manufacturers did not provide us with complete or reliable responses to the CMRT, such matters were reported to members of our executive management team who considered a variety of responses to such manufacturers, including seeking alternative arrangements, with the further input from our internal compliance team. However, we have not yet identified any circumstances to date where it was necessary to terminate a contract or find a replacement contract manufacturer.
| 4. | Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain |
We do not have a direct relationship with any smelters or refiners in our supply chain and, therefore, we do not directly conduct audits. Instead, we have supported the development and implementation of independent third party audits of smelters such as the Conflict-Free Smelter Program by encouraging our contract manufacturers to purchase materials from audited, conflict-free smelters and determining whether the smelters that were used to process these minerals were validated as conflict-free as part of the Conflict-Free Smelter Program.
| 5. | Reporting on Supply Chain Due Diligence |
In 2017, we publicly filed the Form SD and this Report with the SEC, and a copy of this Report and the Form SD are publicly available at http://investor.qualys.com/sec.cfm.
This Report includes information about the RCOI we undertook, our due diligence process designed to conform with the OECD Guidelines, the list of known smelters and refiners utilized in our supply chain identified in our due diligence process, and a description of our products that incorporate Conflict Minerals necessary to the functionality or production of such products.
Findings and Conclusions
Based on the information that was provided by our contract manufacturers and otherwise obtained through the due diligence process, we believe that, to the extent reasonably determinable, the facilities that were used to process the Conflict Minerals contained in the Covered Products included the smelters and refiners listed in Annex I below.
This table includes only facilities that are listed in the CMRT as “known smelters or refineries.” An indication of “Full Compliant” in the far right column of the table indicates that the smelter or refinery has received a “conflict free” designation from an independent third party audit program. An indication of “Active” in the far right column of the table indicates that the smelter or refinery has committed to undergo a CFSP audit or is participating in one of the cross-recognized certification programs: LBMA Responsible Gold Certification or Responsible Jewelry Program Chain-of-Custody Certification. An indication of “Indeterminable” in the far right column of the table indicates that the smelter or refinery was not included in the CFSI compliant or active lists and thus, the facility’s designation is indeterminable.
Because the CFSI lists generally did not indicate individual countries of origin of the Conflict Minerals processed by compliant smelters and refiners, we were not able to determine the countries of origin of the Conflict Minerals processed by the listed compliant smelters and refiners with greater specificity. In addition, for the listed compliant smelters and refiners, origin information is not disclosed by the CFSI. Furthermore, as stated earlier, submission of these smelters by our contract manufacturers does not guarantee that these smelters or refiners are present in the Company’s supply chain as our contract manufacturers were only able to provide company-level CMRTs and not able to provide product-level CMRTs directly linking those smelters or refiners to the Covered Products. Therefore, based on our due diligence efforts, we do not have sufficient information to conclusively determine the countries of origin of the Conflict Minerals contained in the Covered Products or whether the Conflict Minerals in the Covered Products are from recycled or scrap sources.
ANNEX I- SMELTER LIST
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Full Compliant | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Full Compliant | |||
| Gold | AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Full Compliant | |||
| Gold | Argor-Heraeus S.A. | SWITZERLAND | Full Compliant | |||
| Gold | Asahi Pretec Corp. | JAPAN | Full Compliant | |||
| Gold | Asaka Riken Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Indeterminable | |||
| Gold | Aurubis AG | GERMANY | Full Compliant | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Full Compliant | |||
| Gold | Boliden AB | SWEDEN | Full Compliant | |||
| Gold | C. Hafner GmbH + Co. KG | GERMANY | Full Compliant | |||
| Gold | Caridad | MEXICO | Indeterminable | |||
| Gold | CCR Refinery—Glencore Canada Corporation | CANADA | Full Compliant | |||
| Gold | Cendres + Métaux S.A. | SWITZERLAND | Full Compliant | |||
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Chimet S.p.A. | ITALY | Full Compliant | |||
| Gold | Chugai Mining | JAPAN | Indeterminable | |||
| Gold | Daejin Indus Co., Ltd. | KOREA (REPUBLIC OF) | Full Compliant | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | Indeterminable | |||
| Gold | DSC (Do Sung Corporation) | KOREA (REPUBLIC OF) | Full Compliant | |||
| Gold | DODUCO GmbH | GERMANY | Full Compliant | |||
| Gold | Dowa | JAPAN | Full Compliant | |||
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Full Compliant | |||
| Gold | Gansu Seemine Material Hi-Tech Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | Indeterminable | |||
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | Full Compliant | |||
| Gold | Heimerle + Meule GmbH | GERMANY | Full Compliant | |||
| Gold | Heraeus Ltd. Hong Kong | CHINA | Full Compliant | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | Full Compliant | |||
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | Indeterminable | |||
| Gold | HwaSeong CJ Co., Ltd. | KOREA (REPUBLIC OF) | Indeterminable |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Full Compliant | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Istanbul Gold Refinery | TURKEY | Full Compliant | |||
| Gold | Japan Mint | JAPAN | Full Compliant | |||
| Gold | Jiangxi Copper Co., Ltd. | CHINA | Full Compliant | |||
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Asahi Refining Canada Ltd. | CANADA | Full Compliant | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Full Compliant | |||
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | Full Compliant | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | Indeterminable | |||
| Gold | Kazzinc | KAZAKHSTAN | Full Compliant | |||
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | Full Compliant | |||
| Gold | L’azurde Company For Jewelry | SAUDI ARABIA | Indeterminable | |||
| Gold | Lingbao Gold Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | Indeterminable | |||
| Gold | LS-NIKKO Copper Inc. | KOREA (REPUBLIC OF) | Full Compliant | |||
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Materion | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | Full Compliant | |||
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | Full Compliant | |||
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Full Compliant | |||
| Gold | Metalor Technologies S.A. | SWITZERLAND | Full Compliant | |||
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Full Compliant | |||
| Gold | Mitsubishi Materials Corporation | JAPAN | Full Compliant | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Full Compliant | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Full Compliant | |||
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Indeterminable | |||
| Gold | Nihon Material Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Elemetal Refining, LLC | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Full Compliant | |||
| Gold | PAMP S.A. | SWITZERLAND | Full Compliant | |||
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Full Compliant | |||
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | Full Compliant | |||
| Gold | PX Précinox S.A. | SWITZERLAND | Full Compliant | |||
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Full Compliant | |||
| Gold | Royal Canadian Mint | CANADA | Full Compliant | |||
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold | Samduck Precious Metals | KOREA (REPUBLIC OF) | Full Compliant | |||
| Gold | Samwon Metals Corp. | KOREA (REPUBLIC OF) | Indeterminable | |||
| Gold | Schone Edelmetaal B.V. | NETHERLANDS | Full Compliant | |||
| Gold | SEMPSA Joyería Platería S.A. | SPAIN | Full Compliant | |||
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Full Compliant | |||
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Full Compliant | |||
| Gold | So Accurate Group, Inc. | UNITED STATES OF AMERICA | Indeterminable |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Full Compliant | |||
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Full Compliant | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | Full Compliant | |||
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Indeterminable | |||
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Full Compliant | |||
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Indeterminable | |||
| Gold | Torecom | KOREA (REPUBLIC OF) | Full Compliant | |||
| Gold | Umicore Brasil Ltda. | BRAZIL | Full Compliant | |||
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Full Compliant | |||
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | Valcambi S.A. | SWITZERLAND | Full Compliant | |||
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA | Full Compliant | |||
| Gold | Yamamoto Precious Metal Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Yokohama Metal Co., Ltd. | JAPAN | Full Compliant | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Full Compliant | |||
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Full Compliant | |||
| Gold | Morris and Watson | NEW ZEALAND | Indeterminable | |||
| Gold | SAFINA A.S. | CZECH REPUBLIC | Active | |||
| Gold | Guangdong Jinding Gold Limited | CHINA | Indeterminable | |||
| Gold | Umicore Precious Metals Thailand | THAILAND | Full Compliant | |||
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | Full Compliant | |||
| Gold | Republic Metals Corporation | UNITED STATES OF AMERICA | Full Compliant | |||
| Gold | KGHM Polska Miedź Spółka Akcyjna | POLAND | Active | |||
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | Indeterminable | |||
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Full Compliant | |||
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Full Compliant | |||
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | Full Compliant | |||
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | Indeterminable | |||
| Gold | Sudan Gold Refinery | SUDAN | Indeterminable | |||
| Gold | T.C.A S.p.A | ITALY | Full Compliant | |||
| Gold | Remondis Argentia B.V. | NETHERLANDS | Active | |||
| Gold | Tony Goetz NV | BELGIUM | Indeterminable | |||
| Gold | Korea Zinc Co., Ltd. | KOREA (REPUBLIC OF) | Full Compliant | |||
| Gold | Marsam Metals | BRAZIL | Full Compliant | |||
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | Indeterminable | |||
| Gold | SAAMP | FRANCE | Full Compliant | |||
| Gold | L’Orfebre S.A. | ANDORRA | Active | |||
| Gold | Italpreziosi | ITALY | Full Compliant | |||
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | Full Compliant | |||
| Gold | WIELAND Edelmetalle GmbH | GERMANY | Full Compliant | |||
| Gold | Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Full Compliant | |||
| Gold | AU Traders and Refiners | SOUTH AFRICA | Full Compliant | |||
| Gold | AURA-II | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold | Gujarat Gold Centre | INDIA | Indeterminable | |||
| Gold | Sai Refinery | INDIA | Indeterminable | |||
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | Indeterminable | |||
| Gold | Modeltech Sdn Bhd | MALAYSIA | Active | |||
| Gold | Bangalore Refinery | INDIA | Active | |||
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | Full Compliant |
| Gold | Planta Recuperadora de Metales SpA | CHILE | Full Compliant | |||
| Gold | Safimet S.p.A | ITALY | Full Compliant | |||
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | Full Compliant | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA | Full Compliant | |||
| Tantalum | Duoluoshan | CHINA | Indeterminable | |||
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | F&X Electro-Materials Ltd. | CHINA | Full Compliant | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Hi-Temp Specialty Metals, Inc. | UNITED STATES OF AMERICA | Indeterminable | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | King-Tan Tantalum Industry Ltd. | CHINA | Indeterminable | |||
| Tantalum | LSM Brasil S.A. | BRAZIL | Full Compliant | |||
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | Full Compliant | |||
| Tantalum | Mineração Taboca S.A. | BRAZIL | Full Compliant | |||
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | Full Compliant | |||
| Tantalum | Molycorp Silmet A.S. | ESTONIA | Full Compliant | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Full Compliant | |||
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | Full Compliant | |||
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | Full Compliant | |||
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | Indeterminable | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | FIR Metals & Resource Ltd. | CHINA | Full Compliant | |||
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Full Compliant | |||
| Tantalum | KEMET Blue Metals | MEXICO | Full Compliant | |||
| Tantalum | Plansee SE Liezen | AUSTRIA | Indeterminable | |||
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | Full Compliant | |||
| Tantalum | H.C. Starck GmbH Goslar | GERMANY | Full Compliant | |||
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY | Indeterminable | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | Full Compliant | |||
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | H.C. Starck Ltd. | JAPAN | Full Compliant | |||
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | Full Compliant | |||
| Tantalum | Plansee SE Reutte | AUSTRIA | Indeterminable | |||
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | Global Advanced Metals Aizu | JAPAN | Full Compliant | |||
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | Full Compliant | |||
| Tantalum | Tranzact, Inc. | UNITED STATES OF AMERICA | Indeterminable | |||
| Tantalum | Resind Indústria e Comércio Ltda. | BRAZIL | Full Compliant | |||
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | Full Compliant | |||
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | Full Compliant | |||
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Full Compliant | |||
| Tin | CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Indeterminable |
| Tin | Alpha | UNITED STATES OF AMERICA | Full Compliant | |||
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Indeterminable | |||
| Tin | CV Gita Pesona | INDONESIA | Full Compliant | |||
| Tin | PT Justindo | INDONESIA | Indeterminable | |||
| Tin | PT Aries Kencana Sejahtera | INDONESIA | Full Compliant | |||
| Tin | CV Serumpun Sebalai | INDONESIA | Full Compliant | |||
| Tin | CV United Smelting | INDONESIA | Full Compliant | |||
| Tin | Dowa | JAPAN | Full Compliant | |||
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | Full Compliant | |||
| Tin | Estanho de Rondônia S.A. | BRAZIL | Indeterminable | |||
| Tin | Fenix Metals | POLAND | Full Compliant | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Indeterminable | |||
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | Full Compliant | |||
| Tin | China Tin Group Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | Full Compliant | |||
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | Full Compliant | |||
| Tin | Mineração Taboca S.A. | BRAZIL | Full Compliant | |||
| Tin | Minsur | PERU | Full Compliant | |||
| Tin | Mitsubishi Materials Corporation | JAPAN | Full Compliant | |||
| Tin | Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Full Compliant | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Full Compliant | |||
| Tin | Operaciones Metalurgical S.A. | BOLIVIA (PLURINATIONAL STATE OF) | Full Compliant | |||
| Tin | PT Artha Cipta Langgeng | INDONESIA | Full Compliant | |||
| Tin | PT Babel Inti Perkasa | INDONESIA | Full Compliant | |||
| Tin | PT Bangka Tin Industry | INDONESIA | Full Compliant | |||
| Tin | PT Belitung Industri Sejahtera | INDONESIA | Full Compliant | |||
| Tin | PT Bukit Timah | INDONESIA | Full Compliant | |||
| Tin | PT DS Jaya Abadi | INDONESIA | Full Compliant | |||
| Tin | PT Eunindo Usaha Mandiri | INDONESIA | Full Compliant | |||
| Tin | PT Karimun Mining | INDONESIA | Full Compliant | |||
| Tin | PT Mitra Stania Prima | INDONESIA | Full Compliant | |||
| Tin | PT Panca Mega Persada | INDONESIA | Full Compliant | |||
| Tin | PT Prima Timah Utama | INDONESIA | Full Compliant | |||
| Tin | PT Refined Bangka Tin | INDONESIA | Full Compliant | |||
| Tin | PT Sariwiguna Binasentosa | INDONESIA | Full Compliant | |||
| Tin | PT Stanindo Inti Perkasa | INDONESIA | Full Compliant | |||
| Tin | PT Sumber Jaya Indah | INDONESIA | Full Compliant | |||
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA | Full Compliant | |||
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA | Full Compliant | |||
| Tin | PT Tinindo Inter Nusa | INDONESIA | Full Compliant | |||
| Tin | PT Tommy Utama | INDONESIA | Full Compliant | |||
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Full Compliant | |||
| Tin | Soft Metais Ltda. | BRAZIL | Full Compliant | |||
| Tin | Thaisarco | THAILAND | Full Compliant | |||
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Full Compliant | |||
| Tin | VQB Mineral and Trading Group JSC | VIET NAM | Indeterminable | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL | Full Compliant | |||
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Yunnan Tin Company Limited | CHINA | Full Compliant | |||
| Tin | CV Venus Inti Perkasa | INDONESIA | Full Compliant | |||
| Tin | Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Full Compliant | |||
| Tin | PT Wahana Perkit Jaya | INDONESIA | Indeterminable | |||
| Tin | Melt Metais e Ligas S.A. | BRAZIL | Full Compliant | |||
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | Full Compliant | |||
| Tin | Phoenix Metal Ltd. | RWANDA | Indeterminable | |||
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Full Compliant |
| Tin | PT Inti Stania Prima | INDONESIA | Full Compliant | |||
| Tin | CV Ayi Jaya | INDONESIA | Full Compliant | |||
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Indeterminable | |||
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | Indeterminable | |||
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | Indeterminable | |||
| Tin | CV Dua Sekawan | INDONESIA | Full Compliant | |||
| Tin | CV Tiga Sekawan | INDONESIA | Full Compliant | |||
| Tin | PT Cipta Persada Mulia | INDONESIA | Indeterminable | |||
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | Indeterminable | |||
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL | Full Compliant | |||
| Tin | PT O.M. Indonesia | INDONESIA | Indeterminable | |||
| Tin | Metallo-Chimique N.V. | BELGIUM | Full Compliant | |||
| Tin | Elmet S.L.U. | SPAIN | Full Compliant | |||
| Tin | PT Bangka Prima Tin | INDONESIA | Full Compliant | |||
| Tin | PT Sukses Inti Makmur | INDONESIA | Full Compliant | |||
| Tin | An Thai Minerals Co., Ltd. | VIET NAM | Indeterminable | |||
| Tin | PT Kijang Jaya Mandiri | INDONESIA | Full Compliant | |||
| Tin | PT Menara Cipta Mulia | INDONESIA | Full Compliant | |||
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | Full Compliant | |||
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | Full Compliant | |||
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Full Compliant | |||
| Tin | Modeltech Sdn Bhd | MALAYSIA | Active | |||
| Tin | Gejiu Jinye Mineral Company | CHINA | Full Compliant | |||
| Tin | PT Lautan Harmonis Sejahtera | INDONESIA | Full Compliant | |||
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN | Full Compliant | |||
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | Full Compliant | |||
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Full Compliant | |||
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | Full Compliant | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | Full Compliant | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Full Compliant | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Full Compliant | |||
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA | Full Compliant | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Full Compliant |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | Full Compliant | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | H.C. Starck GmbH | GERMANY | Full Compliant | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY | Full Compliant | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Full Compliant | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Full Compliant | |||
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | Full Compliant | |||
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | Full Compliant | |||
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | Full Compliant | |||
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Full Compliant | |||
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Full Compliant | |||
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Full Compliant | |||
| Tungsten | ACL Metais Eireli | BRAZIL | Full Compliant | |||
| Tungsten | Woltech Korea Co., Ltd. | KOREA (REPUBLIC OF) | Full Compliant | |||
| Tungsten | Moliren Ltd | RUSSIAN FEDERATION | Full Compliant | |||
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | Indeterminable |
Future Steps
We have communicated our expectations to our contract manufacturers regarding our commitment to sourcing minerals for our products in a manner that does not finance or benefit armed groups in the Covered Countries. Since the end of 2017, we have continued, and plan to continue, to increase our engagement with our relevant first-tier contract manufacturers in order to build their knowledge and capacity so they are able to provide us with more complete and accurate information on the source and chain of custody of Conflict Minerals in our supply chain.
Additional Risk Factors
The statements above are based on the RCOI process and due diligence performed in good faith by Qualys. These statements are based on the infrastructure and information available at the time. A number of factors could introduce errors or otherwise affect our Conflict Minerals status. These factors include, but are not limited to, gaps in supplier data, gaps in smelter data, errors or omissions by suppliers, errors or omissions by smelters, the definition of a smelter not being finalized at the end of the 2017 reporting period, all instances of Conflict Minerals necessary to the functionality or manufacturing of our products possibly not yet having been identified, gaps in supplier education and knowledge, timeliness of data, public information not discovered during a reasonable search, errors in public data, language barriers and translation, supplier and smelter unfamiliarity with the protocol, oversight or errors in conflict free smelter audits, Covered Countries sourced materials being declared secondary materials, companies going out of business in 2017, certification programs being not equally advanced for all industry segments and metals, and smuggling of Conflict Minerals from the Covered Countries to other countries.