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:
| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2016. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
With respect to the reporting period from January 1, 2016 to December 31, 2016, 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 (“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 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 scrap or recycled 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 January 1, 2016 to December 31, 2016.
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 – 2016 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 26, 2017
EXHIBIT INDEX
| Exhibit |
Description | |
| 1.01 | 2016 Conflict Minerals Report of Qualys, Inc. | |
Exhibit 1.01
Qualys, Inc.
Conflict Minerals Report
For The Reporting Period from January 1, 2016 to December 31, 2016
This Conflict Minerals Report (the “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 January 1, 2016 to December 31, 2016 (“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 leading provider of cloud-based 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 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 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: (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 seven 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, while another manufacturer informed us that it only sourced from those smelters in the Covered Countries that were listed by CFSI as compliant with the Conflict-Free Smelter Program (“CFSP”). Based on the smelter lists provided by our suppliers via the CMRTs, an aggregate of 310 facilities or smelters were used by our contract manufacturers to fulfill their requirements for Conflict Minerals. Of these 310 facilities and smelters, we have identified 241 facilities or smelters that are deemed CFSP-compliant. There are 14 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 55 facilities or smelters identified by our contract manufacturers are not on the CFSI lists for compliant or active smelters. We have assessed these 55 facilities and determined that most of these are of low risk due to their geographic location. There are 4 smelters or refiners that may be considered at greater risk because they are geographically located in Africa. However, there is no guarantee that these 55 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 scrap or recycled 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/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 seven 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 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 2016, 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 “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 indicated 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
| Metal | Smelter Name | Smelter Country | Status | |||
| Gold |
Cendres + Métaux S.A. | SWITZERLAND | Active | |||
| Gold |
Navoi Mining and Metallurgical Combinat | UZBEKISTAN | Active | |||
| Gold |
KGHM Polska Miedź Spółka Akcyjna | POLAND | Active | |||
| Gold |
Tony Goetz NV | BELGIUM | Active | |||
| Gold |
Modeltech Sdn Bhd | MALAYSIA | Active | |||
| Gold |
Bangalore Refinery | INDIA | Active | |||
| Gold |
Advanced Chemical Company | UNITED STATES OF AMERICA | Compliant | |||
| Gold |
Aida Chemical Industries Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | Compliant | |||
| Gold |
Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | Compliant | |||
| Gold |
AngloGold Ashanti Córrego do Sítio Mineração | BRAZIL | Compliant | |||
| Gold |
Argor-Heraeus S.A. | SWITZERLAND | Compliant | |||
| Gold |
Asahi Pretec Corp. | JAPAN | Compliant | |||
| Gold |
Asaka Riken Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Aurubis AG | GERMANY | Compliant | |||
| Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | Compliant | |||
| Gold |
Boliden AB | SWEDEN | Compliant | |||
| Gold |
C. Hafner GmbH + Co. KG | GERMANY | Compliant | |||
| Gold |
CCR Refinery - Glencore Canada Corporation | CANADA | Compliant | |||
| Gold |
Chimet S.p.A. | ITALY | Compliant | |||
| Gold |
Daejin Indus Co., Ltd. | KOREA (REPUBLIC OF) | Compliant | |||
| Gold |
DSC (Do Sung Corporation) | KOREA (REPUBLIC OF) | Compliant | |||
| Gold |
DODUCO GmbH | GERMANY | Compliant | |||
| Gold |
Dowa | JAPAN | Compliant | |||
| Gold |
Eco-System Recycling Co., Ltd. | JAPAN | Compliant |
| Gold |
OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | Compliant | |||
| Gold |
Heimerle + Meule GmbH | GERMANY | Compliant | |||
| Gold |
Heraeus Ltd. Hong Kong | CHINA | Compliant | |||
| Gold |
Heraeus Precious Metals GmbH & Co. KG | GERMANY | Compliant | |||
| Gold |
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | Compliant | |||
| Gold |
Ishifuku Metal Industry Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Istanbul Gold Refinery | TURKEY | Compliant | |||
| Gold |
Japan Mint | JAPAN | Compliant | |||
| Gold |
Jiangxi Copper Co., Ltd. | CHINA | Compliant | |||
| Gold |
Asahi Refining USA Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Gold |
Asahi Refining Canada Ltd. | CANADA | Compliant | |||
| Gold |
JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | Compliant | |||
| Gold |
JSC Uralelectromed | RUSSIAN FEDERATION | Compliant | |||
| Gold |
JX Nippon Mining & Metals Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Kazzinc | KAZAKHSTAN | Compliant | |||
| Gold |
Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | Compliant | |||
| Gold |
Kojima Chemicals Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Kyrgyzaltyn JSC | KYRGYZSTAN | Compliant | |||
| Gold |
LS-NIKKO Copper Inc. | KOREA (REPUBLIC OF) | Compliant | |||
| Gold |
Materion | UNITED STATES OF AMERICA | Compliant | |||
| Gold |
Matsuda Sangyo Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Metalor Technologies (Suzhou) Ltd. | CHINA | Compliant | |||
| Gold |
Metalor Technologies (Hong Kong) Ltd. | CHINA | Compliant | |||
| Gold |
Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | Compliant | |||
| Gold |
Metalor Technologies S.A. | SWITZERLAND | Compliant | |||
| Gold |
Metalor USA Refining Corporation | UNITED STATES OF AMERICA | Compliant | |||
| Gold |
Metalúrgica Met-Mex Peñoles S.A. De C.V. | MEXICO | Compliant | |||
| Gold |
Mitsubishi Materials Corporation | JAPAN | Compliant | |||
| Gold |
Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | Compliant | |||
| Gold |
Nadir Metal Rafineri San. Ve Tic. A.Ş. | TURKEY | Compliant | |||
| Gold |
Nihon Material Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Ohura Precious Metal Industry Co., Ltd. | JAPAN | Compliant | |||
| Gold |
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet) | RUSSIAN FEDERATION | Compliant | |||
| Gold |
PAMP S.A. | SWITZERLAND | Compliant | |||
| Gold |
Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | Compliant | |||
| Gold |
PT Aneka Tambang (Persero) Tbk | INDONESIA | Compliant | |||
| Gold |
PX Précinox S.A. | SWITZERLAND | Compliant | |||
| Gold |
Rand Refinery (Pty) Ltd. | SOUTH AFRICA | Compliant | |||
| Gold |
Royal Canadian Mint | CANADA | Compliant | |||
| Gold |
Samduck Precious Metals | KOREA (REPUBLIC OF) | Compliant | |||
| Gold |
Schone Edelmetaal B.V. | NETHERLANDS | Compliant | |||
| Gold |
SEMPSA Joyería Platería S.A. | SPAIN | Compliant | |||
| Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | Compliant | |||
| Gold |
Sichuan Tianze Precious Metals Co., Ltd. | CHINA | Compliant | |||
| Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | Compliant | |||
| Gold |
Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | Compliant | |||
| Gold |
Sumitomo Metal Mining Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Tanaka Kikinzoku Kogyo K.K. | JAPAN | Compliant | |||
| Gold |
The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | Compliant | |||
| Gold |
Tokuriki Honten Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Torecom | KOREA (REPUBLIC OF) | Compliant | |||
| Gold |
Umicore Brasil Ltda. | BRAZIL | Compliant | |||
| Gold |
Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | Compliant | |||
| Gold |
United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Gold |
Valcambi S.A. | SWITZERLAND | Compliant | |||
| Gold |
Western Australian Mint trading as The Perth Mint | AUSTRALIA | Compliant | |||
| Gold |
Yamamoto Precious Metal Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Yokohama Metal Co., Ltd. | JAPAN | Compliant | |||
| Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | Compliant | |||
| Gold |
Zijin Mining Group Co., Ltd. Gold Refinery | CHINA | Compliant | |||
| Gold |
Umicore Precious Metals Thailand | THAILAND | Compliant | |||
| Gold |
Geib Refining Corporation | UNITED STATES OF AMERICA | Compliant | |||
| Gold |
MMTC-PAMP India Pvt., Ltd. | INDIA | Compliant | |||
| Gold |
Republic Metals Corporation | UNITED STATES OF AMERICA | Compliant | |||
| Gold |
Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | Compliant |
| Gold |
Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | Compliant | |||
| Gold |
Emirates Gold DMCC | UNITED ARAB EMIRATES | Compliant | |||
| Gold |
T.C.A S.p.A | ITALY | Compliant | |||
| Gold |
Korea Zinc Co., Ltd. | KOREA (REPUBLIC OF) | Compliant | |||
| Gold |
SAXONIA Edelmetalle GmbH | GERMANY | Compliant | |||
| Gold |
WIELAND Edelmetalle GmbH | GERMANY | Compliant | |||
| Gold |
Ögussa Österreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | Compliant | |||
| Gold |
AU Traders and Refiners | SOUTH AFRICA | Compliant | |||
| Gold |
Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | Indeterminable | |||
| Gold |
Caridad | MEXICO | Indeterminable | |||
| Gold |
Yunnan Copper Industry Co., Ltd. | CHINA | Indeterminable | |||
| Gold |
Chugai Mining | JAPAN | Indeterminable | |||
| Gold |
Daye Non-Ferrous Metals Mining Ltd. | CHINA | Indeterminable | |||
| 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 |
Hunan Chenzhou Mining Co., Ltd. | CHINA | Indeterminable | |||
| Gold |
HwaSeong CJ Co., Ltd. | KOREA (REPUBLIC OF) | Indeterminable | |||
| Gold |
Kazakhmys Smelting LLC | KAZAKHSTAN | Indeterminable | |||
| 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 |
Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | Indeterminable | |||
| Gold |
Elemetal Refining, LLC | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold |
Penglai Penggang Gold Industry Co., Ltd. | CHINA | Indeterminable | |||
| Gold |
Sabin Metal Corp. | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold |
Samwon Metals Corp. | KOREA (REPUBLIC OF) | Indeterminable | |||
| Gold |
Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | Indeterminable | |||
| Gold |
So Accurate Group, Inc. | UNITED STATES OF AMERICA | Indeterminable | |||
| Gold |
Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | Indeterminable | |||
| Gold |
Tongling Nonferrous Metals Group Co., Ltd. | CHINA | Indeterminable | |||
| Gold |
Morris and Watson | NEW ZEALAND | Indeterminable | |||
| Gold |
SAFINA A.S. | CZECH REPUBLIC | Indeterminable | |||
| Gold |
Guangdong Jinding Gold Limited | CHINA | Indeterminable | |||
| Gold |
Fidelity Printers and Refiners Ltd. | ZIMBABWE | Indeterminable | |||
| Gold |
Kaloti Precious Metals | UNITED ARAB EMIRATES | Indeterminable | |||
| Gold |
Sudan Gold Refinery | SUDAN | Indeterminable | |||
| Gold |
Remondis Argentia B.V. | NETHERLANDS | Indeterminable | |||
| Gold |
TOO Tau-Ken-Altyn | KAZAKHSTAN | Indeterminable | |||
| Gold |
SAAMP | FRANCE | Indeterminable | |||
| 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 | |||
| Tantalum |
Changsha South Tantalum Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
Conghua Tantalum and Niobium Smeltry | CHINA | Compliant | |||
| Tantalum |
Duoluoshan | CHINA | Compliant | |||
| Tantalum |
Exotech Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum |
F&X Electro-Materials Ltd. | CHINA | Compliant | |||
| Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
Hi-Temp Specialty Metals, Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
Jiujiang Tanbre Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
King-Tan Tantalum Industry Ltd. | CHINA | Compliant | |||
| Tantalum |
LSM Brasil S.A. | BRAZIL | Compliant | |||
| Tantalum |
Metallurgical Products India Pvt., Ltd. | INDIA | Compliant | |||
| Tantalum |
Mineração Taboca S.A. | BRAZIL | Compliant | |||
| Tantalum |
Mitsui Mining and Smelting Co., Ltd. | JAPAN | Compliant | |||
| Tantalum |
Molycorp Silmet A.S. | ESTONIA | Compliant | |||
| Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
QuantumClean | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum |
RFH Tantalum Smeltry Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | Compliant | |||
| Tantalum |
Taki Chemical Co., Ltd. | JAPAN | Compliant | |||
| Tantalum |
Telex Metals | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum |
Ulba Metallurgical Plant JSC | KAZAKHSTAN | Compliant |
| Tantalum |
Zhuzhou Cemented Carbide Group Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
D Block Metals, LLC | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum |
FIR Metals & Resource Ltd. | CHINA | Compliant | |||
| Tantalum |
Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
XinXing HaoRong Electronic Material Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | Compliant | |||
| Tantalum |
KEMET Blue Metals | MEXICO | Compliant | |||
| Tantalum |
H.C. Starck Co., Ltd. | THAILAND | Compliant | |||
| Tantalum |
H.C. Starck GmbH Goslar | GERMANY | Compliant | |||
| Tantalum |
H.C. Starck Hermsdorf GmbH | GERMANY | Compliant | |||
| Tantalum |
H.C. Starck Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum |
H.C. Starck Ltd. | JAPAN | Compliant | |||
| Tantalum |
H.C. Starck Smelting GmbH & Co. KG | GERMANY | Compliant | |||
| Tantalum |
Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum |
Global Advanced Metals Aizu | JAPAN | Compliant | |||
| Tantalum |
KEMET Blue Powder | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum |
Tranzact, Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Tantalum |
Resind Indústria e Comércio Ltda. | BRAZIL | Compliant | |||
| Tantalum |
Jiangxi Tuohong New Raw Material | CHINA | Compliant | |||
| Tantalum |
Power Resources Ltd. | MACEDONIA (THE FORMER YUGOSLAV REPUBLIC OF) | Compliant | |||
| Tantalum |
Plansee SE Liezen | AUSTRIA | Indeterminable | |||
| Tantalum |
H.C. Starck GmbH Laufenburg | GERMANY | Indeterminable | |||
| Tantalum |
Plansee SE Reutte | AUSTRIA | Indeterminable | |||
| Tin |
Huichang Jinshunda Tin Co., Ltd. | CHINA | Active | |||
| Tin |
Gejiu Kai Meng Industry and Trade LLC | CHINA | Active | |||
| Tin |
Nankang Nanshan Tin Manufactory Co., Ltd. | CHINA | Active | |||
| Tin |
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | Active | |||
| Tin |
Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | Active | |||
| Tin |
Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM | Active | |||
| Tin |
Modeltech Sdn Bhd | MALAYSIA | Active | |||
| Tin |
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | Compliant | |||
| Tin |
Jiangxi Ketai Advanced Material Co., Ltd. | CHINA | Compliant | |||
| Tin |
Alpha | UNITED STATES OF AMERICA | Compliant | |||
| Tin |
Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL | Compliant | |||
| Tin |
CV Gita Pesona | INDONESIA | Compliant | |||
| Tin |
PT Aries Kencana Sejahtera | INDONESIA | Compliant | |||
| Tin |
CV Serumpun Sebalai | INDONESIA | Compliant | |||
| Tin |
CV United Smelting | INDONESIA | Compliant | |||
| Tin |
Dowa | JAPAN | Compliant | |||
| Tin |
EM Vinto | Compliant | ||||
| Tin |
Fenix Metals | POLAND | Compliant | |||
| Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | Compliant | |||
| Tin |
China Tin Group Co., Ltd. | CHINA | Compliant | |||
| Tin |
Malaysia Smelting Corporation (MSC) | MALAYSIA | Compliant | |||
| Tin |
Metallic Resources, Inc. | UNITED STATES OF AMERICA | Compliant | |||
| Tin |
Mineração Taboca S.A. | BRAZIL | Compliant | |||
| Tin |
Minsur | PERU | Compliant | |||
| Tin |
Mitsubishi Materials Corporation | JAPAN | Compliant | |||
| Tin |
O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | Compliant | |||
| Tin |
Operaciones Metalurgical S.A. | Compliant | ||||
| Tin |
PT Artha Cipta Langgeng | INDONESIA | Compliant | |||
| Tin |
PT Babel Inti Perkasa | INDONESIA | Compliant | |||
| Tin |
PT Bangka Tin Industry | INDONESIA | Compliant | |||
| Tin |
PT Belitung Industri Sejahtera | INDONESIA | Compliant | |||
| Tin |
PT Bukit Timah | INDONESIA | Compliant | |||
| Tin |
PT DS Jaya Abadi | INDONESIA | Compliant | |||
| Tin |
PT Eunindo Usaha Mandiri | INDONESIA | Compliant | |||
| Tin |
PT Karimun Mining | INDONESIA | Compliant | |||
| Tin |
PT Mitra Stania Prima | INDONESIA | Compliant | |||
| Tin |
PT Panca Mega Persada | INDONESIA | Compliant | |||
| Tin |
PT Prima Timah Utama | INDONESIA | Compliant | |||
| Tin |
PT Refined Bangka Tin | INDONESIA | Compliant | |||
| Tin |
PT Sariwiguna Binasentosa | INDONESIA | Compliant | |||
| Tin |
PT Stanindo Inti Perkasa | INDONESIA | Compliant | |||
| Tin |
PT Sumber Jaya Indah | INDONESIA | Compliant |
| Tin |
PT Timah (Persero) Tbk Kundur | INDONESIA | Compliant | |||
| Tin |
PT Timah (Persero) Tbk Mentok | INDONESIA | Compliant | |||
| Tin |
PT Tinindo Inter Nusa | INDONESIA | Compliant | |||
| Tin |
PT Tommy Utama | INDONESIA | Compliant | |||
| Tin |
Rui Da Hung | TAIWAN, PROVINCE OF CHINA | Compliant | |||
| Tin |
Soft Metais Ltda. | BRAZIL | Compliant | |||
| Tin |
Thaisarco | THAILAND | Compliant | |||
| Tin |
VQB Mineral and Trading Group JSC | VIET NAM | Compliant | |||
| Tin |
White Solder Metalurgia e Mineração Ltda. | BRAZIL | Compliant | |||
| Tin |
Yunnan Tin Company Limited | CHINA | Compliant | |||
| Tin |
CV Venus Inti Perkasa | INDONESIA | Compliant | |||
| Tin |
Magnu’s Minerais Metais e Ligas Ltda. | BRAZIL | Compliant | |||
| Tin |
Melt Metais e Ligas S.A. | BRAZIL | Compliant | |||
| Tin |
PT ATD Makmur Mandiri Jaya | INDONESIA | Compliant | |||
| Tin |
O.M. Manufacturing Philippines, Inc. | PHILIPPINES | Compliant | |||
| Tin |
PT Inti Stania Prima | INDONESIA | Compliant | |||
| Tin |
CV Ayi Jaya | INDONESIA | Compliant | |||
| Tin |
CV Dua Sekawan | INDONESIA | Compliant | |||
| Tin |
CV Tiga Sekawan | INDONESIA | Compliant | |||
| Tin |
Resind Indústria e Comércio Ltda. | BRAZIL | Compliant | |||
| Tin |
PT O.M. Indonesia | INDONESIA | Compliant | |||
| Tin |
Metallo-Chimique N.V. | BELGIUM | Compliant | |||
| Tin |
Elmet S.L.U. | SPAIN | Compliant | |||
| Tin |
PT Bangka Prima Tin | INDONESIA | Compliant | |||
| Tin |
PT Sukses Inti Makmur | INDONESIA | Compliant | |||
| Tin |
PT Kijang Jaya Mandiri | INDONESIA | Compliant | |||
| Tin |
HuiChang Hill Tin Industry Co., Ltd. | CHINA | Compliant | |||
| Tin |
Gejiu Fengming Metallurgy Chemical Plant | CHINA | Compliant | |||
| Tin |
Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | Compliant | |||
| Tin |
Gejiu Jinye Mineral Company | CHINA | Compliant | |||
| Tin |
CNMC (Guangxi) PGMA Co., Ltd. | CHINA | Indeterminable | |||
| Tin |
PT Justindo | INDONESIA | Indeterminable | |||
| Tin |
Estanho de Rondônia S.A. | BRAZIL | Indeterminable | |||
| Tin |
Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | Indeterminable | |||
| Tin |
PT Tirus Putra Mandiri | INDONESIA | Indeterminable | |||
| Tin |
PT Wahana Perkit Jaya | INDONESIA | Indeterminable | |||
| Tin |
Phoenix Metal Ltd. | RWANDA | 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 |
PT Cipta Persada Mulia | INDONESIA | Indeterminable | |||
| Tin |
An Vinh Joint Stock Mineral Processing Company | VIET NAM | Indeterminable | |||
| Tin |
An Thai Minerals Co., Ltd. | VIET NAM | Indeterminable | |||
| Tungsten |
ACL Metais Eireli | BRAZIL | Active | |||
| Tungsten |
A.L.M.T. TUNGSTEN Corp. | JAPAN | Compliant | |||
| Tungsten |
Kennametal Huntsville | UNITED STATES OF AMERICA | Compliant | |||
| Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Fujian Jinxin Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | Compliant | |||
| Tungsten |
Hunan Chenzhou Mining Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Japan New Metals Co., Ltd. | JAPAN | Compliant | |||
| Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Kennametal Fallon | UNITED STATES OF AMERICA | Compliant | |||
| Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | Compliant | |||
| Tungsten |
Vietnam Youngsun Tungsten Industry Co., Ltd. | VIET NAM | Compliant | |||
| Tungsten |
Wolfram Bergbau und Hütten AG | AUSTRIA | Compliant | |||
| Tungsten |
Xiamen Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Malipo Haiyu Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Asia Tungsten Products Vietnam Ltd. | VIET NAM | Compliant |
| Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
H.C. Starck GmbH | GERMANY | Compliant | |||
| Tungsten |
H.C. Starck Smelting GmbH & Co.KG | GERMANY | Compliant | |||
| Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIET NAM | Compliant | |||
| Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | Compliant | |||
| Tungsten |
Niagara Refining LLC | UNITED STATES OF AMERICA | Compliant | |||
| Tungsten |
Hydrometallurg, JSC | RUSSIAN FEDERATION | Compliant | |||
| Tungsten |
South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | Compliant | |||
| Tungsten |
Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | Compliant | |||
| Tungsten |
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | Compliant | |||
| Tungsten |
Woltech Korea Co., Ltd. | KOREA (REPUBLIC OF) | Compliant | |||
| Tungsten |
Moliren Ltd | RUSSIAN FEDERATION | Compliant | |||
| Tungsten |
Dayu Weiliang Tungsten Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten |
Jiangxi Minmetals Gao’an Non-ferrous Metals Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten |
Ganzhou Yatai Tungsten Co., Ltd. | CHINA | Indeterminable | |||
| Tungsten |
Jiangxi Dayu Longxintai Tungsten 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 2016, 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 2016 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 2016, certification programs being not equally advanced for all industry segments and metals, and smuggling of Conflict Minerals from the Covered Countries to other countries.