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) |
(Commission File Number) |
(IRS Employer Identification No.) |
1600 Bridge Parkway, Redwood City, California 94065
(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:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
With respect to the reporting period from January 1, 2014 to December 31, 2014, Qualys, Inc. (“Qualys” or 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 (“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 whether the products that we manufacture which contain any gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives (“Conflict Minerals”) originate from the Democratic Republic of Congo, the Republic of Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola (collectively, the “Covered Countries”). Based on such due diligence, we determined that our products are DRC Conflict Undeterminable with regard to calendar year 2014 because we were unable to comprehensively determine the origin of all Conflict Minerals used in our products, the facilities used to process them, their country of origin, and their mine or location of origin.
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 January 1, 2014 to December 31, 2014.
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 report.
Section 2 – Exhibits
The following exhibit is filed as part of this report.
Item 2.01 Exhibits.
Exhibit 1.01 – 2014 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: June 1, 2015
EXHIBIT INDEX
| Exhibit No. |
Description | |
| 1.01 | 2014 Conflict Minerals Report of Qualys, Inc. | |
Exhibit 1.01
Qualys, Inc.
Conflict Minerals Report
For The Reporting Period from January 1, 2014 to December 31, 2014
This Conflict Minerals Report (the “Report”) of Qualys, Inc. (“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 January 1, 2014 to December 31, 2014.
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and 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 and wolframite, including 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 leading provider of cloud security and compliance solutions that enable organizations to identify security risks to their 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 QualysGuard 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 QualysGuard Cloud Platform to cost-effectively obtain a unified view of their security and compliance posture across globally-distributed IT infrastructures.
As part of our cloud platform, we host and operate a large number of globally distributed physical scanner appliances that our customers use to scan their externally facing systems and web applications. To scan internal IT assets, customers can also deploy our scanners, which are available on a subscription basis as physical appliances or downloadable virtual images, within their internal networks. Our scanner appliances self-update daily in a transparent manner using our automated and proprietary scan management technology. These scanner appliances allow us to scale our cloud platform to scan networked devices and web applications across organizations’ networks around the world.
Description of the Company’s Products Covered by this Report
This Report relates to our managed scanner appliances that were manufactured, or contracted to be manufactured, by the Company and for which the manufacture was completed during calendar year 2014. We refer to these products in this Report as “Covered Products.”
Description of the Company’s Reasonable Country of Origin Inquiry
As described in this Report, we have determined that gold, tantalum, tin, and tungsten are necessary to the functionality or production of products manufactured or contracted to be manufactured by us during the calendar year 2014. 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. The Company does not directly purchase Conflict Minerals from mines, smelters or refiners. Therefore, the Company must rely on its 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 minerals reporting template prepared by the Electronic Industry Citizenship Coalition and Global eSustainability Initiative (“EICC-GeSI”) 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 this template and we received responses from five of our contract manufacturers affirmatively indicating that none of the necessary Conflict Minerals included in our Covered Products that we contract to manufacture originated from the Covered Countries. Our remaining three contract manufacturers did not provide sufficient information to determine the facilities used to process the Conflict Minerals contained in our Covered Products.
Based on our RCOI, and in light of the responses we received from our contract manufacturers discussed above, we were unable to determine that the Conflict Minerals did not originate in the Covered Countries, or if our Conflict Minerals came from recycled or scrap sources.
Description of the Company’s Due Diligence Process
Based on this information, 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 determined that our products are DRC Conflict Undeterminable with regard to calendar year 2014 because we were unable to comprehensively determine 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/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 EICC-GeSI template 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. With respect to our contract manufacturers that were unable to provide us with sufficient information to determine the facilities used to process the Conflict Minerals contained in our Covered Products, we have communicated that we are evaluating such responses and may elect to seek alternative arrangements with other contract manufacturers to the extent any such contract manufacturers are unable to cooperate with us in our due diligence efforts. |
| 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, which we anticipate will include our Conflict Minerals policy, once available. |
| 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 are in the process of developing a formal risk management plan though which our conflict minerals program will be implemented, managed and monitored. During calendar year 2014, when our contract manufacturers did not provide us with complete or reliable responses to the EICC-GeSI template, 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 (“CFSP”) 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 2014, 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 EICC-GeSI template as “known smelters or refineries,” or in the United States Department of Commerce’s global list of “all known conflict mineral processing facilities worldwide.” A “Yes” 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 as of March 18, 2014. A “No” in the far right column of the table indicates that the smelter or refinery has not received a “conflict free” designation from an independent third party audit program or the facility’s receipt of such designation is undeterminable.
Though based on the information received from our RCOI due diligence process, we do not have sufficient information to determine whether the Conflict Minerals originated in the Covered Countries, or came from recycled or scrap sources, we believe that the Conflict Minerals were sourced from the countries listed in Annex II below, in addition to recycled or scrap sources.
ANNEX I
| Metal |
Smelter or Refiner Facility Name |
Location |
“Conflict Free” | |||
| Gold | Aida Chemical Industries Co. Ltd. | Japan | No | |||
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | Yes | |||
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | No | |||
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | Brazil | Yes | |||
| Gold | Argor-Heraeus SA | Switzerland | Yes | |||
| Gold | Asahi Pretec Corporation | Japan | Yes | |||
| Gold | Asaka Riken Co Ltd | Japan | No | |||
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | Yes | |||
| Gold | Aurubis AG | Germany | Yes | |||
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | No | |||
| Gold | Bauer Walser AG | Germany | No | |||
| Gold | Boliden AB | Sweden | Yes | |||
| Gold | C. Hafner GmbH + Co. KG | Germany | Yes | |||
| Gold | Caridad | Mexico | No | |||
| Gold | CCR Refinery – Glencore Canada Corporation | Canada | Yes | |||
| Gold | Cendres & Métaux SA | Switzerland | No | |||
| Gold | Chimet S.p.A. | Italy | Yes | |||
| Gold | China National Gold Group Corporation | China | No | |||
| Gold | Chugai Mining | Japan | No | |||
| Gold | Colt Refining | United States | No | |||
| Gold | Daejin Indus Co. Ltd | Korea, Republic of | No | |||
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China | No | |||
| Gold | Do Sung Corporation | Korea, Republic of | No | |||
| Gold | Doduco | Germany | No | |||
| Gold | Dowa Metals & Mining Co., Ltd. | Japan | Yes | |||
| Gold | Eco-System Recycling Co., Ltd. | Japan | Yes | |||
| Gold | FSE Novosibirsk Refinery | Russian Federation | No | |||
| Gold | Gansu Seemine Material Hi-Tech Co. Ltd. | China | No | |||
| Gold | Guangdong Jinding Gold Limited | China | No | |||
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | No | |||
| Gold | Heimerle + Meule GmbH | Germany | Yes | |||
| Gold | Heraeus Ltd. Hong Kong | Hong Kong | Yes | |||
| Gold | Heraeus Precious Metals GmbH & Co. KG | Germany | Yes | |||
| Gold | Hunan Chenzhou Mining Group Co., Ltd. | China | No | |||
| Gold | Hwasung CJ Co. Ltd | Korea, Republic of | No | |||
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | China | No | |||
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan | Yes | |||
| Gold | Istanbul Gold Refinery | Turkey | Yes | |||
| Gold | Japan Mint | Japan | Yes | |||
| Gold | Jiangxi Copper Company Limited | China | No | |||
| Gold | Johnson Matthey Inc | United States | Yes | |||
| Gold | Johnson Matthey Ltd | Canada | Yes | |||
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | Yes | |||
| Gold | JSC Uralectromed | Russian Federation | No | |||
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan | Yes | |||
| Gold | Kazzinc Ltd | Kazakhstan | Yes | |||
| Gold | Kennecott Utah Copper LLC | United States | Yes | |||
| Gold | Kojima Chemicals Co., Ltd | Japan | Yes | |||
| Gold | Korea Metal Co. Ltd | Korea, Republic of | No | |||
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan | No |
| Metal |
Smelter or Refiner Facility Name |
Location |
“Conflict Free” | |||
| Gold | L’ azurde Company For Jewelry | Saudi Arabia | Yes | |||
| Gold | Lingbao Gold Company Limited | China | No | |||
| Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | China | No | |||
| Gold | LS-Nikko Copper Inc. | Korea, Republic of | Yes | |||
| Gold | Luoyang Zijin Yinhui Metal Smelt Co Ltd | China | No | |||
| Gold | Materion | United States | Yes | |||
| Gold | Matsuda Sangyo Co., Ltd. | Japan | Yes | |||
| Gold | Metalor Technologies (Hong Kong) Ltd | Hong Kong | Yes | |||
| Gold | Metalor Technologies (Singapore) Pte. Ltd. | Singapore | Yes | |||
| Gold | Metalor Technologies SA | Switzerland | Yes | |||
| Gold | Metalor Switzerland | Switzerland | Yes | |||
| Gold | Metalor USA Refining Corporation | United States | Yes | |||
| Gold | Metalurgica Met-Mex Penoles, S.A. DE C.V. | Mexico | Yes | |||
| Gold | Met-Mex Peñoles, S.A. | Mexico | Yes | |||
| Gold | Mitsubishi Materials Corporation | Japan | Yes | |||
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan | Yes | |||
| Gold | Moscow Special Alloys Processing Plant | Russian Federation | No | |||
| Gold | Nadir Metal Rafineri San. Ve Tic. A.Ş. | Turkey | Yes | |||
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan | No | |||
| Gold | Nihon Material Co. Ltd | Japan | Yes | |||
| Gold | Ohio Precious Metals, LLC | United States | Yes | |||
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan | Yes | |||
| Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | Russian Federation | Yes | |||
| Gold | OJSC Kolyma Refinery | Russian Federation | No | |||
| Gold | PAMP SA | Switzerland | Yes | |||
| Gold | Penglai Penggang Gold Industry Co Ltd | China | No | |||
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation | No | |||
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia | Yes | |||
| Gold | PX Précinox SA | Switzerland | Yes | |||
| Gold | Rand Refinery (Pty) Ltd | South Africa | Yes | |||
| Gold | Royal Canadian Mint | Canada | Yes | |||
| Gold | Sabin Metal Corp. | United States | No | |||
| Gold | SAMWON METALS Corp. | Korea, Republic of | No | |||
| Gold | Schone Edelmetaal | Netherlands | Yes | |||
| Gold | SEMPSA Joyería Platería SA | Spain | Yes | |||
| Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | China | Yes | |||
| Gold | So Accurate Group, Inc. | United States | No | |||
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | No | |||
| Gold | Solar Applied Materials Technology Corp. | Taiwan | Yes | |||
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan | Yes | |||
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan | Yes | |||
| Gold | The Great Wall Gold and Silver Refinery of China | China | No | |||
| Gold | The Refinery of Shandong Gold Mining Co. Ltd | China | Yes | |||
| Gold | Tokuriki Honten Co., Ltd | Japan | Yes | |||
| Gold | Tongling Nonferrous Metals Group Co., Ltd | China | No | |||
| Gold | Torecom | Korea, Republic of | No | |||
| Gold | Umicore Brasil Ltda | Brazil | Yes | |||
| Gold | Umicore Precious Metals Thailand | Thailand | Yes | |||
| Gold | Umicore SA Business Unit Precious Metals Refining | Belgium | Yes | |||
| Gold | United Precious Metal Refining, Inc. | United States | Yes | |||
| Gold | Valcambi SA | Switzerland | Yes | |||
| Gold | Western Australian Mint trading as The Perth Mint | Australia | Yes | |||
| Gold | Yamamoto Precious Metal Co., Ltd. | Japan | No | |||
| Gold | Yokohama Metal Co Ltd | Japan | No |
| Metal |
Smelter or Refiner Facility Name |
Location |
“Conflict Free” | |||
| Gold | Yunnan Copper Industry Co. Ltd. | China | No | |||
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | No | |||
| Gold | Zijin Mining Group Co. Ltd | China | No | |||
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | China | Yes | |||
| Tantalum | Conghua Tantalum and Niobium Smeltry | China | Yes | |||
| Tantalum | Duoluoshan | China | Yes | |||
| Tantalum | Exotech Inc. | United States | Yes | |||
| Tantalum | F&X Electro-Materials Ltd. | China | Yes | |||
| Tantalum | Global Advanced Metals | United States | No | |||
| Tantalum | Global Advanced Metals Aizu | Japan | Yes | |||
| Tantalum | Global Advanced Metals Boyertown | United States | Yes | |||
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China | Yes | |||
| Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | China | Yes | |||
| Tantalum | H.C. Starck Co., Ltd. | Thailand | Yes | |||
| Tantalum | H.C. Starck GmbH Goslar | Germany | Yes | |||
| Tantalum | H.C. Starck GmbH Laufenburg | Germany | Yes | |||
| Tantalum | H.C. Starck Group | Germany | No | |||
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany | Yes | |||
| Tantalum | H.C. Starck Inc. | United States | Yes | |||
| Tantalum | H.C. Starck Ltd. | Japan | Yes | |||
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | Germany | Yes | |||
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Yes | |||
| Tantalum | Hi-Temp | United States | Yes | |||
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Yes | |||
| Tantalum | JiuJiang Tanbre Co., Ltd. | China | Yes | |||
| Tantalum | Kemet Blue Metals | Mexico | Yes | |||
| Tantalum | Kemet Blue Powder | United States | Yes | |||
| Tantalum | King-tan Tantalum Industry Ltd. | China | No | |||
| Tantalum | LSM Brazil S.A. | Brazil | Yes | |||
| Tantalum | Metallurgical Products India (Pvt.) Ltd. | India | Yes | |||
| Tantalum | Mineração Taboca S.A. | Brazil | Yes | |||
| Tantalum | Mitsui Mining & Smelting | Japan | Yes | |||
| Tantalum | Molycorp Silmet A.S. | Estonia | Yes | |||
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China | Yes | |||
| Tantalum | Plansee | Austria | No | |||
| Tantalum | Plansee SE Liezen | Austria | Yes | |||
| Tantalum | Plansee SE Reutte | Austria | Yes | |||
| Tantalum | QuantumClean | United States | Yes | |||
| Tantalum | RFH Tantalum Smeltry Co., Ltd | China | Yes | |||
| Tantalum | Shanghai Jiangxi Metals Co. Ltd | China | No | |||
| Tantalum | Solikamsk Magnesium Works OAO | Russian Federation | Yes | |||
| Tantalum | Solikamsk Metal Works | Russian Federation | Yes | |||
| Tantalum | Taki Chemical Co., Ltd. | Japan | Yes | |||
| Tantalum | Telex | United States | Yes | |||
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan | Yes | |||
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd | China | Yes | |||
| Tantalum | Zhuzhou Cement Carbide | China | Yes | |||
| Tin | Alpha | United States | Yes | |||
| Tin | China Rare Metal Materials Company | China | No | |||
| Tin | China Tin Group Co., Ltd. | China | No | |||
| Tin | CNMC (Guangxi) PGMA Co. Ltd. | China | No | |||
| Tin | Cooper Santa | Brazil | No | |||
| Tin | CV Gita Pesona | Indonesia | No | |||
| Tin | CV JusTindo | Indonesia | No |
| Metal |
Smelter or Refiner Facility Name |
Location |
“Conflict Free” | |||
| Tin | CV Makmur Jaya | Indonesia | No | |||
| Tin | CV Nurjanah | Indonesia | No | |||
| Tin | CV Serumpun Sebalai | Indonesia | No | |||
| Tin | CV United Smelting | Indonesia | Yes | |||
| Tin | Dowa | Japan | Yes | |||
| Tin | EM Vinto | Bolivia | Yes | |||
| Tin | Estanho de Rondônia S.A. | Brazil | No | |||
| Tin | Fenix Metals | Poland | No | |||
| Tin | Gejiu Kai Meng Industry and Trade LLC | China | No | |||
| Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | China | Yes | |||
| Tin | Gejiu Zi-Li | China | No | |||
| Tin | Huichang Jinshunda Tin Co. Ltd | China | No | |||
| Tin | Jiangxi Nanshan | China | No | |||
| Tin | Linwu Xianggui Smelter Co | China | No | |||
| Tin | Magnu’s Minerais Metais e Ligas LTDA | Brazil | Yes | |||
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia | Yes | |||
| Tin | Melt Metals e Ligas S/A | Brazil | Yes | |||
| Tin | Metallo Chimique | Belgium | Yes | |||
| Tin | Mineração Taboca S.A. | Brazil | Yes | |||
| Tin | Minsur | Peru | Yes | |||
| Tin | Mitsubishi Materials Corporation | Japan | Yes | |||
| Tin | Novosibirsk Integrated Tin Works | Russian Federation | No | |||
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | No | |||
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines | No | |||
| Tin | OMSA | Bolivia | Yes | |||
| Tin | PT Alam Lestari Kencana | Indonesia | No | |||
| Tin | PT Artha Cipta Langgeng | Indonesia | No | |||
| Tin | PT ATD Makmur Mandiri Jaya | Indonesia | Yes | |||
| Tin | PT Babel Inti Perkasa | Indonesia | Yes | |||
| Tin | PT Babel Surya Alam Lestari | Indonesia | No | |||
| Tin | PT Bangka Kudai Tin | Indonesia | No | |||
| Tin | PT Bangka Putra Karya | Indonesia | Yes | |||
| Tin | PT Bangka Timah Utama Sejahtera | Indonesia | No | |||
| Tin | PT Bangka Tin Industry | Indonesia | Yes | |||
| Tin | PT Belitung Industri Sejahtera | Indonesia | No | |||
| Tin | PT BilliTin Makmur Lestari | Indonesia | No | |||
| Tin | PT Bukit Timah | Indonesia | Yes | |||
| Tin | PT DS Jaya Abadi | Indonesia | Yes | |||
| Tin | PT Eunindo Usaha Mandiri | Indonesia | Yes | |||
| Tin | PT Fang Di MulTindo | Indonesia | No | |||
| Tin | PT HP Metals Indonesia | Indonesia | No | |||
| Tin | PT Inti Stania Prima | Indonesia | No | |||
| Tin | PT Karimun Mining | Indonesia | No | |||
| Tin | PT Koba Tin | Indonesia | No | |||
| Tin | PT Mitra Stania Prima | Indonesia | No | |||
| Tin | PT Panca Mega Persada | Indonesia | No | |||
| Tin | PT Pelat Timah Nusantara Tbk | Indonesia | No | |||
| Tin | PT Prima Timah Utama | Indonesia | Yes | |||
| Tin | PT Refined Bangka Tin | Indonesia | Yes | |||
| Tin | PT Sariwiguna Binasentosa | Indonesia | Yes | |||
| Tin | PT Seirama Tin Investment | Indonesia | No | |||
| Tin | PT Stanindo Inti Perkasa | Indonesia | Yes | |||
| Tin | PT Sumber Jaya Indah | Indonesia | No | |||
| Tin | PT Supra Sukses Trinusa | Indonesia | No |
| Metal |
Smelter or Refiner Facility Name |
Location |
“Conflict Free” | |||
| Tin | PT Tambang Timah | Indonesia | Yes | |||
| Tin | PT Timah (Persero), Tbk | Indonesia | Yes | |||
| Tin | PT Tinindo Inter Nusa | Indonesia | No | |||
| Tin | PT Tommy Utama | Indonesia | No | |||
| Tin | PT Yinchendo Mining Industry | Indonesia | No | |||
| Tin | Rui Da Hung | Taiwan | No | |||
| Tin | Soft Metais, Ltda. | Brazil | No | |||
| Tin | Thaisarco | Thailand | Yes | |||
| Tin | White Solder Metalurgia e Mineração Ltda. | Brazil | Yes | |||
| Tin | Yunnan Chengfeng Non-Ferrous Metals Co.,Ltd. | China | No | |||
| Tin | Yunnan Tin Company, Ltd. | China | Yes | |||
| Tungsten | A.L.M.T. Corp. | Japan | Yes | |||
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Yes | |||
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Yes | |||
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | China | Yes | |||
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China | Yes | |||
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | Yes | |||
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Yes | |||
| Tungsten | Ganzhou Non-Ferrous Metals Smelting Co., Ltd. | China | Yes | |||
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China | Yes | |||
| Tungsten | Global Tungsten & Powders Corp. | United States | Yes | |||
| Tungsten | Guangdong Xianglu Tungsten Industry Co., Ltd. | China | Yes | |||
| Tungsten | HC Starck GmbH | Germany | No | |||
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | Germany | No | |||
| Tungsten | H.C. Starck GmbH | Germany | No | |||
| Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | China | Yes | |||
| Tungsten | Hunan Chun-Chang Nonferrous Smelting & Concentrating Co., Ltd. | China | Yes | |||
| Tungsten | Japan New Metals Co., Ltd. | Japan | Yes | |||
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | No | |||
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Yes | |||
| Tungsten | Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | China | No | |||
| Tungsten | Jiangxi Richsea New Materials Co., Ltd. | China | No | |||
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | No | |||
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | No | |||
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Yes | |||
| Tungsten | Kennametal Fallon | United States | No | |||
| Tungsten | Kennametal Huntsville | United States | No | |||
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China | Yes | |||
| Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Vietnam | No | |||
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam | Yes | |||
| Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | Vietnam | Yes | |||
| Tungsten | Wolfram Bergbau und Hütten AG | Austria | Yes | |||
| Tungsten | Wolfram Company CJSC | Russian Federation | Yes | |||
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China | Yes | |||
| Tungsten | Xiamen Tungsten Co., Ltd. | China | Yes | |||
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | China | Yes | |||
| Tungsten | Zhuzhou Cemented Carbide Group Co Ltd | China | No |
ANNEX II
| Australia |
Korea | |
| Belgium |
Malaysia | |
| Bolivia |
Mexico | |
| Brazil |
Philippines | |
| Britain |
Portugal | |
| Canada |
Russia | |
| Chile |
Spain | |
| China |
Switzerland | |
| Great Britain |
Thailand | |
| Indonesia |
United States | |
| Japan |
||
DRC Conflict Undeterminable
After exercising the due diligence described above, we were unable to determine whether or not each of the Covered Products qualify as “DRC conflict free,” as defined under the Rule. Accordingly, we have reasonably determined that each of the Covered Products is “DRC conflict undeterminable,” as defined in the Rule.
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 and we are currently considering developing a more formal Conflict Minerals policy. Since the end of 2014, 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 2014 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 due to this being the first year for SEC disclosures for Section 1502 of Dodd-Frank, oversights or errors in conflict free smelter audits, Covered Countries sourced materials being declared secondary materials, companies going out of business in 2014, certification programs being not equally advanced for all industry segments and metals, and smuggling of Conflict Minerals from the Covered Countries to countries beyond the covered countries.