UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
AVNET, INC.
(Exact name of registrant as specified in its charter)
| New York | 1-4224 | 11-1890605 | ||
| (State or other jurisdiction | (Commission File Number) | (IRS Employer | ||
| of incorporation or organization) | Identification No.) |
| 2211 South 47th Street, Phoenix, Arizona | 85034 | |
| (Address of principal executive offices) | (Zip Code) |
Joy Newborg
Associate General Counsel
(480) 643-2000
(Name and telephone number, including area code,
of the person to contact in connection with this report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021. |
Section 1 – Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
This Specialized Disclosure Report on Form SD and the Conflict Minerals Report, filed as Exhibit 1.01, is filed by Avnet, Inc. (collectively with its consolidated subsidiaries, the “Company”) pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (“Conflict Minerals Rule”), for the calendar year ended December 31, 2021, and is posted on the Company’s website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals. Information contained on, or accessible through, the Company’s website is neither part of nor incorporated by reference into this Report.
Item 1.02 Exhibit
The Conflict Minerals Report described in Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits
| Exhibit Number |
Description | |
| 1.01 | Conflict Minerals Report for the calendar year ended December 31, 2021. |
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SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.
| Date: May 26, 2022 | By: | /s/ Thomas Liguori |
|
Thomas Liguori Chief Financial officer | ||
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Exhibit 1.01
CONFLICT MINERALS REPORT
For the Reporting Period from January 1 to December 31, 2021
Introduction
This is the Conflict Minerals Report of Avnet, Inc. for the calendar year 2021 (“Report”), which has been filed as an exhibit to the Company’s Form SD as provided for in Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”) and is posted on the Company’s website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals. Information contained on, or accessible through, the Company’s website is neither part of nor incorporated by reference into this Report. The date of filing of this Report is May 26, 2022.
References in this Report to “the Company,” “Avnet,” “we,” “our,” or “us” means Avnet, Inc. together with its subsidiaries, except where the context otherwise requires.
Applicability of the Conflict Minerals Rule to Avnet
Avnet is a global technology distributor and solutions provider that supports customers at every stage of the product lifecycle, from idea to design and from prototype to production. Its unique position at the center of the technology value chain enables it to accelerate the design and supply stages of product development so customers can realize revenue faster. A core part of Avnet’s business is as a global distributor of electronic components. It markets, sells and distributes electronic components from the world’s leading electronic component manufacturers, including semiconductors, IP&E components (interconnect, passive and eletromechanical), and other integrated and embedded components, and distributes a comprehensive portfolio of kits, tools, industrial automation components, and test and measurement products. It also provides embedded solutions, such as technical design, integration and assembly of embedded products, systems, and solutions; provides integrated solutions for embedded display solutions, such as touch and passive displays; and develops and produces standard board, industrial subsystems and application-specific devices.
The Conflict Minerals Rule requires that the Company disclose in an annual Form SD and associated Conflict Minerals Report information regarding any conflict minerals that are “necessary to the functionality or production” of any product that it manufactures or contracts to be manufactured. The Securities and Exchange Commission (“SEC”) defines conflict minerals as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten (collectively, “CMs”). The Democratic Republic of Congo and its adjoining countries have extensive reserves of CMs, some of which are illegally sourced and traded by armed groups who are responsible for significant human rights violations. The purpose of the Conflict Minerals Rule is to encourage companies whose products contain CMs to endeavor to source from suppliers who do not directly or indirectly support such armed groups through their purchasing decisions. The term CM refers to the named minerals and their derivatives, and does not infer that the procurement of such minerals or derivatives directly or indirectly financed or benefitted armed groups in the Democratic Republic of Congo or an adjoining country. CMs are used in many electronic components and computer products.
Avnet’s revenues for 2021 were largely from distribution and services that were not in-scope for purposes of compliance with the Conflict Minerals Rule. However, it manufactured or contracted to manufacture certain products in which CMs were necessary to the functionality or production of those products during 2021 (collectively, “Covered Products”). Therefore, the Company conducted a reasonable country of origin inquiry (“RCOI”), in good faith, to determine whether any of the CMs in the Covered Products: (1) originated in the Democratic Republic of Congo or an adjoining country, including Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia (collectively, the “Covered Countries”); or (2) are from recycled or scrap sources. Please see “Conflict Minerals Program – Reasonable Country of Origin Inquiry” for more information on the RCOI.
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The Company conducted further due diligence on the source and chain of custody of such CMs that conformed, in all material respects, to an internationally recognized due diligence framework as required by the Conflict Minerals Rule. Please see “Conflict Minerals Program – Design of Conflict Minerals Program” for more information on the design of the due diligence program and “Conflict Minerals Program – Due Diligence Efforts” for more information on the due diligence conducted.
Avnet is a downstream consumer of CMs. It does not purchase the necessary CMs contained in its Covered Products directly from mines, smelters or refiners and is generally many levels removed from such market participants. Through the efforts described in this Report, Avnet seeks to ensure that its sourcing practices are consistent with its Responsible Minerals Sourcing Policy and to encourage conflict free sourcing in its supply chain.
Responsible Minerals Sourcing Policy
Avnet is committed to responsible sourcing of CMs and promotes traceability of CMs and transparency of its global supply chain. It supports the efforts of the Responsible Business Alliance’s (“RBA”) due diligence and reporting processes that seek to ensure supply chain transparency. In addition, the Company has actively engaged with its customers and suppliers for several years with respect to the use of CMs, and has adopted a Responsible Minerals Sourcing Policy, which has been communicated to Avnet’s suppliers and the public. The Responsible Minerals Sourcing Policy is below:
Avnet, Inc., including its subsidiaries (collectively “Avnet”), is committed to source minerals responsibly and avoid sourcing minerals that contribute to armed conflict or human rights abuses in conflict affected and high-risk areas (CAHRAs), including the Democratic Republic of Congo (DRC) or adjoining countries. Avnet’s approach is to promote the traceability and transparency of supply chains and move towards a conflict-free global supply chain.
Avnet supports the aims of the Responsible Business Alliance’s Responsible Minerals Initiative (RMI) to identify, reduce and eventually eliminate the use of conflict minerals that finance or benefit conflict or human rights violations, and the Responsible Minerals Assurance Process (RMAP) to validate responsible sources. Avnet encourages its suppliers to likewise support such efforts. “Conflict minerals” include tantalum, tin, tungsten and gold, which are used in many electronic components and computer products.
Under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the U.S. Securities and Exchange Commission (“SEC”) rules, Avnet is required to annually report on Form SD whether products it manufactures or contracts to manufacture contain conflict minerals necessary to the functionality or production of the products, which have been sourced from mines in the DRC or adjoining countries (“covered products”). Revenue from the mining and trade of conflict minerals from the DRC or adjoining countries is believed to finance or benefit armed groups that are responsible for human rights violations.
Avnet is a global technology distributor and solutions provider. To a very limited extent Avnet manufactures or contracts to manufacture products, some of which are covered products. However, Avnet is a downstream consumer of conflict minerals. It does not purchase directly from mines, smelters or refiners and is many levels removed from such market participants. Avnet endeavors to avoid purchasing products containing conflict minerals sourced from CAHRAs that directly or indirectly finance or benefit armed groups, while minimizing unintended consequences of de facto embargoes for conflict-free mines. Avnet also expects its suppliers to source minerals only from responsible sources.
Avnet annually conducts a reasonable country of origin inquiry (RCOI) and due diligence that aligns with the Organisation for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Framework). As a downstream consumer, Avnet expects its suppliers to provide proper verification of the country of origin and source of the conflict minerals used in the products they supply to Avnet, utilizing the most current Conflict Minerals Reporting Template (CMRT) developed by RMI. Avnet also encourages its suppliers to adopt similar policies, due diligence frameworks, and management systems with respect to responsible minerals sourcing to drive those efforts throughout their supply chain.
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The Responsible Minerals Sourcing Policy is available on the Company’s website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals.
Conflict Minerals Program
Design of Conflict Minerals Program
Avnet’s 2021 Conflict Minerals Program (“2021 Program”) utilized the internationally recognized framework The Organization for Economic Co-Operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Framework”) to develop its process to identify the country of origin and chain of custody of the CMs.
As Avnet does not purchase CMs directly from any mine, refiner or smelter, its supply chain with respect to the CMs in its Covered Products is highly complex and there are many parties in the supply chain between Avnet’s direct supplier and the mine from which the CM originated. Due to the Company’s “downstream” position in the supply chain, it followed the principles outlined in the OECD Framework for downstream companies with no direct relationships to smelters or refiners. Therefore, Avnet must rely, in good faith, on its direct suppliers to provide it with information regarding the country of origin and chain of custody of the CMs included in the Covered Products and on third-party audit programs. It is likely that years of engagement and propagation of expectations through many tiers of the supply chain will be necessary before information returned to downstream companies, such as Avnet, may be considered accurate and complete.
Covered Products
Avnet determined that the following products it manufactured or contracted to manufacture in 2021 contained CMs necessary to the functionality or production of those products, which are referred to as the Covered Products:
| ● | Electromechanical solutions manufactured or contracted to be manufactured by DEM Manufacturing. |
| ● | Test tools for development engineers incorporating wireless charging functionality using the Wireless Power Consortium “Qi” technology contracted to be manufactured for AVID. |
| ● | Semi-conductor electronic devices designed and contracted to be manufactured by Avnet per customer specifications. |
| ● | Electronic boards, electronic devices and display solutions manufactured or contracted to be manufactured by Avnet Embedded GmbH and put on the market under the brand “MSC”. |
| ● | Control boards and Human-Machine Interfaces (HMIs) contracted to be manufactured. |
| ● | Server based products integrated from customer designed and/or off-the-shelf components by Avnet Integrated. |
| ● | Design kits manufactured or contracted to be manufactured by Avnet. |
| ● | Sphere module and development kit, Sphere Guardian products, and IOT Gateway products designed by Avnet IoT team and manufactured or contracted to be manufactured by Avnet Products & Emerging Technologies. |
| ● | Development boards and design kits manufactured or contracted to be manufactured by Avnet Silica. |
| ● | Development boards manufactured or contracted to be manufactured by EBV Elektronik. |
| ● | Development boards and accessories contracted to be manufactured by Avnet. |
Covered Products do not include products that were not entered into the stream of commerce in 2021, and do not include products manufactured or contracted to be manufactured by entities acquired by Avnet after April 2021, as provided by the Conflict Minerals Rule.
Reasonable Country of Origin Inquiry
Pursuant to the Conflict Minerals Rule, Avnet conducted a RCOI on the source and chain of custody of the CMs in its Covered Products, to determine whether any of the necessary CMs in its Covered Products originated in any of the Covered Countries and may not have come from recycled or scrap sources. To the extent applicable, Avnet conducted its RCOI utilizing the same processes and procedures that it established for conducting its due diligence, in particular Steps 1 and 2 of the OECD Framework, which are described under “Due Diligence Efforts” below.
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The 2021 RCOI included 454 suppliers (“Suppliers”) that Avnet identified as possibly providing it with components, parts or products that contained the necessary CMs for its Covered Products. These Suppliers identified smelters and refiners that may have processed the necessary CMs contained in the Covered Products. Such smelters and refiners were compared against the Smelter Look-up tab of the Conflict Minerals Reporting Template (“CMRT”) and the list of “conformant” smelters and refiners and country of origin information published by the RBA’s Responsible Minerals Initiative (“RMI”) to validate the smelters and refiners, which validated facilities are listed in Appendix A, and to determine the countries from where such validated facilities may have obtained CMs, which countries are listed in Appendix B. For this process, Avnet utilized the data its Suppliers provided on their CMRTs version 6.10 or higher along with RMI’s due diligence of smelters and refiners and audits under the Responsible Minerals Assurance Process (“RMAP”) standard. The RMAP uses an independent third-party audit of smelter and refiner management systems and sourcing practices to validate conformance with RMAP protocols and current global standards.
The Company retained Assent Compliance (“Assent”), a third-party service provider, to assist in the collection and review of Supplier CMRTs and the identification of risks in the supply chain. During the 2021 RCOI, Avnet contacted Suppliers via the Assent Compliance Manager (“ACM”), a software-as-a-service platform that enables users to manage and track supplier communications and allows suppliers to upload completed CMRTs directly to the platform for validation, assessment and management. ACM provides functionality that meets the OECD Framework process expectations by evaluating the quality of each Supplier’s response and assigning a health score based on the Supplier’s declaration of process engagement. Additionally, the results provided in this Report, as well as the step-by-step process for Supplier engagement and upstream due diligence investigations performed, are managed through ACM.
Avnet requested that all Suppliers complete a CMRT. On behalf of Avnet, Assent offered training and educational resources to Suppliers to guide them on best practices, completion of a CMRT and the use of the ACM platform. Avnet monitored and tracked all communications in ACM for future reporting and transparency. If a Supplier remained unresponsive after three requests through ACM, Avnet may directly follow-up with such Supplier.
Supplier CMRTs are subjected to an automated data validation process, with the goal to increase the completeness and accuracy of submissions and identify any contradictory answers in a CMRT. This data validation process is based on questions within the declaration tab of the CMRT, which helps to identify areas that require further classification or risk assessment as well as to understand the due diligence efforts of the Suppliers. Data validation contributes to the health assessment of Avnet’s Conflict Minerals Program, and the results are shared with Suppliers regarding areas that require clarification or improvement.
Submitted Supplier CMRTs are accepted and classified as either valid or invalid. If a Supplier’s CMRT is classified as invalid, the Supplier is provided feedback and guidance on how to correct the validation errors and requested to re-submit a valid CMRT. In addition, Suppliers are provided training courses and direct engagement help through Assent’s multilingual Supplier Experience team.
Due Diligence Efforts
Based on the findings of the 2021 RCOI, pursuant to the Conflict Minerals Rule, Avnet conducted further due diligence on the source and chain of custody of the CMs in its Covered Products. The Company designed its due diligence measures to conform, in all material respects, with the OECD Framework, which contains a five-step structure for due diligence as a basis for responsible global supply chain management of CMs from conflict-affected and high-risk areas.
1. Establish strong company management systems
| ● | Avnet has a governance team and a working team to carry out its Conflict Minerals Program. The governance team is responsible for ensuring that the program meets regulatory requirements and enterprise goals and provides direction to the working team. The working team is responsible for the day-to-day execution of the program, diligence efforts and risk mitigation strategy. |
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| ● | Avnet utilizes a third-party service provider, Assent, to assist with collecting and evaluating supply chain information, identifying potential risks and developing additional due diligence steps. Please see “Conflict Minerals Program – Reasonable Country of Origin Inquiry” for more information on the utilization of Assent and its software platform ACM. |
| ● | Avnet has a Responsible Minerals Sourcing Policy, as discussed earlier in this Report. Pursuant to this policy, Avnet expects its Suppliers to source CMs only from responsible sources and to provide proper verification of the country of origin and source of the materials used in the products they supply to Avnet. Suppliers either receive a copy of the policy or are notified of this policy. In addition, the policy is posted on Avnet’s website. |
| ● | Avnet seeks to include CM related provisions in new or amended supplier agreements with respect to the Covered Products. Its current form of supplier agreement contains a CM provision that requires a Supplier to warrant that any products it supplies containing CMs either does not finance or benefit armed groups in the Covered Countries or are from recycled or scrap sources. |
| ● | Avnet utilizes the current CMRT version developed by RMI to identify smelters and refiners in its supply chain. The CMRT requires Suppliers to provide information concerning the usage and source of CMs in their components, parts and products, as well as information concerning their related compliance efforts, including whether they have a policy on conflict-free sourcing and required their own suppliers to source CMs from responsible sources. |
| ● | By utilizing Assent, Avnet provides its Suppliers access to a free platform to upload their CMRTs, help desk support, educational resources on how to properly complete and submit a CMRT, and other multilingual resources. |
| ● | Employees, vendors, suppliers, customers and any third-party can confidentially report concerns regarding Avnet’s business operations, including compliance with the Responsible Minerals Sourcing Policy, through the Ethics Alertline, via phone or internet. Violations or grievances at the industry level can be reported to the RMI directly at http://responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/. |
| ● | Avnet has a document retention policy to retain CM related documents, including supplier responses to CMRTs and the sources identified within each reporting period, for at least five years. |
2. Identify and assess risk in the supply chain
| ● | Avnet identifies the business segments that manufacture or contract to manufacture products reasonably believed to contain CMs and determine the Covered Products subject to the Conflict Minerals Rule. As a global value-added distributor, a significant percentage of Avnet’s operations are out of scope of the Conflict Minerals Rule. |
| ● | Avnet identifies the active suppliers of materials, components, parts, and products that may contain CMs for the Covered Products, and each Supplier is requested to complete the then latest revision of the CMRT. Avnet expects its direct Suppliers to survey their suppliers. |
| ● | Supplier level risks include non-responsive suppliers. Avnet tracks receipt of Supplier CMRTs, and if a Supplier remains unresponsive after three requests through the ACM platform, Avnet directly follows-up with such Supplier. Follow-up with non-responsive Suppliers continued into 2022. |
| ● | Submitted CMRTs go through a data validation process to evaluate responses for plausibility, completion and consistency to lower the risks associated with Supplier CMRT content and for predetermined red flag indicators defined in the OECD Framework to identify risks to the supply chain posed by smelters. To the extent that a CMRT is incomplete, invalid or other relevant information is not provided by a Supplier, follow-up procedures are undertaken to request compliance and to offer feedback, guidance and educational resources. Follow-up with such Suppliers continued into 2022. |
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| ● | Based on a Supplier’s submitted CMRT, the strength of a Supplier’s related compliance efforts, including whether it has a conflict minerals sourcing policy or implements due diligence measures for conflict free sourcing, is evaluated, tracked and rated as either weak or strong. |
| ● | Supplier level risks also include Supplier CMRTs that are based on company-level information versus Covered Product-level information. Suppliers may have been over-inclusive if their suppliers provide information on a company-level basis and under-inclusive if Suppliers experience non-responsive suppliers or incomplete supplier CMRTs. Therefore, the Company is unable to determine if the smelters and refiners listed in Appendix A were all utilized or is a complete list of smelters and refiners utilized for CMs in the Covered Products. |
| ● | Smelters and refiners identified in the CMRTs are compared against the Smelter Look-up tab of the CMRT and the list of Conformant smelters and refiners and country of origin information published by the RMI to determine if the smelter had been audited against a standard in conformance with the OECD Framework, such as RMAP. |
| ● | If a smelter’s due diligence practices have not been audited against the RMAP standard or the smelter is considered non-conformant by RMAP, Assent conducts follow-ups with suppliers reporting those facilities and the facilities are assessed for potential sourcing risks. |
3. Design and implementation of a strategy to respond to identified risks
| ● | Avnet has a risk management plan through which the Conflict Minerals Program is implemented, managed and monitored. The plan includes processes to assess and respond to the risks identified in the supply chain, which are described in more detail under “Due Diligence Efforts – 2. Identify and assess risk in the supply chain”. |
| ● | Working team leaders monitor and report on risk to certain members of senior management. |
| ● | Avnet’s Responsible Minerals Sourcing Policy publicly announces its expectations that Suppliers participate in Avnet’s due diligence process by providing proper verification of the country of origin and source of the materials used in the Covered Products they supply to Avnet. The policy also states that Suppliers are expected to source CMs only from responsible sources. |
| ● | Avnet seeks to include CM related provisions in new or amended supplier agreements with respect to the Covered Products and include CM related due diligence in acquisition activities. |
| ● | Avnet works with Suppliers on an as-needed basis to assist them with understanding the requirements of the Conflict Minerals Rule. Avnet also offers, through Assent, training and educational resources to Suppliers to guide them on best practices, completion of a CMRT and the use of the ACM platform. |
| ● | Avnet has processes in place for new product introductions and changes to the bill of materials for the Covered Products to help ensure compliance with the Conflict Minerals Program. |
| ● | Avnet participates in Assent’s smelter outreach initiative, where letters are sent twice a year to each smelter and refiner not conformant or not enrolled in RMAP to encourage participation in a cross-recognized industry audit program. The initiative also includes letters to smelters and refiners who are conformant to RMAP to reflect appreciation for their efforts. |
| ● | Employees, vendors, suppliers, customers and any third-party can confidentially report concerns regarding Avnet’s business operations, including compliance with the Responsible Minerals Sourcing Policy, through the Ethics Alertline, via phone or internet. |
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4. Carry out independent third-party audit of supply chain due diligence
| ● | As Avnet is a downstream consumer of CMs and is generally many steps removed from smelters and refiners which provide minerals and ores, Avnet is not positioned to conduct direct audits of smelters and refiners’ due diligence practices. Instead, it relies on initiatives such as those led by RBA, including RMI, to conduct smelter and refinery due diligence audits. |
5. Report annually on supply chain due diligence
| ● | Avnet annually files a Form SD and a Conflict Minerals Report with the SEC and makes them available to the public on its website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals. |
Results of 2021 Conflict Minerals Program
As a downstream purchaser of components, parts and products that may contain CMs, Avnet’s 2021 Program can provide only reasonable, but not absolute, assurance regarding the country of origin and chain of custody of the necessary CMs in its Covered Products.
The due diligence process is based on Avnet requesting information from its direct Suppliers, with those Suppliers requesting similar information from their suppliers and so on, up the supply chain, to eventually identify the original sources of the necessary CMs. However, those who purchase CMs directly from smelters or refiners may not be able to discern which of its product lines include specific CMs from each smelter or refiner, and so it is common practice for such purchasers to list all smelters and refiners they may purchase from within the reporting period. Likewise, Suppliers’ CMRTs primarily provided information at the company level, with few at the product level, and Suppliers may have received similar information from their suppliers and so on. Therefore, Avnet must rely, in good faith, on its direct Suppliers to provide it with valid and complete information. Finally, not all Suppliers completed CMRTs or completed CMRTs in full for the 2021 Program.
For the 2021 Program, 454 Suppliers were identified, of which 263 (or 57.9%) submitted a completed CMRT.
| Supplier CMRT Results | |||||||||||||||||||||
| Year of Program | # Suppliers in Scope | # Completed CMRTs | % Completed CMRTs | # Valid CMRTs | % Valid CMRTs | ||||||||||||||||
| 2021 | 454 | 263 | 57.9% | 251 | 55.3% | ||||||||||||||||
| Strength of Supplier CM Program Results | |||||||||||||||||||||
| Year of Program | # Completed CMRTS | # Suppliers with CM programs and policies rated as strong | # Suppliers with no CMs in their products | Total Suppliers with strong CM programs/policies or no CMs in products | % of such Suppliers | ||||||||||||||||
| 2021 | 263 | 193 | 39 | 232 | 88.2% | ||||||||||||||||
The 335 legitimate smelters and refiners identified by Suppliers in completed CMRTs, which appear on the RMI-maintained smelters list, are listed in Appendix A. Based on the limitations explained above, this list may be more comprehensive than the list of smelters and refiners which actually processed the CMs contained in the Covered Products. The below table summarizes the number of such legitimate smelters and refiners which have been audited, are in the process of being audited, or not enrolled to be audited by RMI utilizing the RMAP standard as well as audit results.
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| Smelter and Refiner Audit Status Results (1) | ||||||||
| RMI Audit Status | Legitimate Smelters and Refiners | |||||||
| RMAP Conformant (2) | 231 | 68.96 | % | |||||
| RMAP Active (3) | 18 | 5.37 | % | |||||
| Non-Conformant (4) | 17 | 5.07 | % | |||||
| Not Enrolled (roll up of the statuses below) | 69 | 20.60 | % | |||||
| Total | 335 | 100.00 | % | |||||
| Not Enrolled subcategories | Count | |||
| Communication Suspended - Not Interested(5) | 6 | |||
| Due Diligence Vetting Process (6) | 0 | |||
| In Communication (7) | 13 | |||
| Outreach Required (8) | 46 | |||
| RMI Due Diligence Review - Unable to Proceed (9) | 4 | |||
(1) The compliance status information provided in the table is based solely on information made available by RMI, without independent verification by the Company.
(2) ) “Conformant” means that the smelter or refiner has completed the independent annual audit process and been found to be in conformance with the relevant RMAP standard, whereby verified to have conflict-free sources.
(3) “Active” means that the smelter or refiner is in the process of being independently audited or has committed to begin the audit process but has not yet been determined to be in conformance with the relevant RMAP standard.
(4) “Non-Conformant” means that the smelter or refiner has been independently assessed but found not to be in conformance with the relevant RMAP standard.
(5) “Communication Suspended – Not Interested” means the smelter or refiner has strongly communicated a lack of interest in participating in the audit program.
(6) “Due Diligence Vetting Process” means the smelter or refiner does not meet RMI’s requirements for participation in the audit program according to the Due Diligence Vetting Process.
(7) “In Communication” means the smelter or refiner is not yet active but is in communications with RMAP and/or a member company.
(8) “Outreach Required” means RMI member companies need to contact entity to encourage their participation in audit program.
(9) “RMI Due Diligence Review – Unable to Proceed” means the smelter or refiner has not met the thresholds for the Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted.
The aggregated list of countries of origin from which the reported smelters and refiners may have collectively sourced CMs, based on information provided through the CMRT data collection process and RMAP audits, is provided in Appendix B. Based on the limitations explained above, this list may be more comprehensive than the list of countries from which CMs contained in the Covered Products were actually sourced.
After conducting its 2021 Program, and in light of the limitations explained above, Avnet concludes that it is unable to determine the origin of the CMs contained in its Covered Products and unable to determine whether its Covered Products are DRC conflict free.
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Steps to be taken in Calendar 2022
As Avnet endeavors not to purchase products that contain CMs that directly or indirectly finance or benefit armed groups in the Covered Countries, and in order to mitigate the risk of purchasing such products, it has continued with its Conflict Minerals Program discussed above during calendar year 2022 and specifically plans to pursue the following steps and improvements:
| ● | Continue to engage with Suppliers that provided incomplete responses or no responses for 2021 to help encourage them to provide requested information for 2022. |
| ● | For Suppliers whose conflict minerals compliance programs and policies are deemed weak, continue to follow-up with such Suppliers to encourage them to improve their efforts and policies. |
| ● | For new in-scope suppliers, to communicate Avnet’s sourcing expectations, including through the dissemination of the Responsible Minerals Sourcing Policy and inclusion of CM sourcing requirements in supplier agreements, and provide access to training and educational resources on the requirements of the Conflict Minerals Rule and to guide them on best practices, completion of a CMRT and the use of the ACM platform. |
| ● | Proactively analyze whether any CMs are present in future products that it develops or in existing products to the extent the materials included in such existing products are revised. |
| ● | Proactively seek to include CM related provisions in new or amended supplier agreements with respect to the Covered Products. |
| ● | Continue to monitor its Ethics Alertline for issues related to the Company’s conflict minerals program. |
Cautionary Statement about Forward-Looking Statements
Certain statements in this Report may be “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. Words such as “expects,” “intends,” “plans,” “believes,” “anticipates” and similar expressions, or the use of future tense, are used to identify these forward-looking statements. Examples of forward-looking statements include statements relating to the Company’s future plans, additional steps it intends to take to mitigate the risk that the Company’s necessary CMs benefit armed groups and other statements that do not relate to historical or current facts.
Forward-looking statements are based on the Company’s current expectations and assumptions, which may not prove to be accurate. These statements are not guarantees and are subject to risks, uncertainties and changes in circumstances that are difficult to predict, including: (1) the continued implementation of satisfactory traceability and other compliance measures by Avnet’s direct and indirect suppliers on a timely basis or at all, (2) whether smelters, refiners and other market participants responsibly source CMs and (3) political and regulatory developments regarding CMs. Actual outcomes and results may differ materially from these forward-looking statements. As a result, these statements speak only as of the date they are made and the Company undertakes no obligation to update or revise any forward-looking statement, except as required by federal securities law.
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APPENDIX A
List of Smelters and Refiners
Avnet utilized data its Suppliers provided on their CMRTs for the 2021 Program along with RBA’s RMI due diligence of smelters and refiners to prepare the below list. The list: (1) may not include all of the smelters and refiners that processed CMs in the Covered Products and (2) may include smelters and refiners which processed CMs which were not contained in the products provided by the Suppliers for the Covered Products.
For RMI Audit Status:
(1) “Conformant” means that the smelter or refiner has completed the independent annual audit process and been found to be in conformance with the relevant RMAP standard, whereby verified to have conflict-free sources.
(2) “Active” means that the smelter or refiner is in the process of being independently audited or has committed to begin the audit process but has not yet been determined to be in conformance with the relevant RMAP standard.
(3) “Non-Conformant” means that the smelter or refiner has been independently assessed but found not to be in conformance with the relevant RMAP standard.
(4) “Communication Suspended – Not Interested” means the smelter or refiner has strongly communicated a lack of interest in participating in the audit program.
(5) “Due Diligence Vetting Process” means the smelter or refiner does not meet RMI’s requirements for participation in the audit program according to the Due Diligence Vetting Process.
(6) “In Communication” means the smelter or refiner is not yet active but is in communications with RMAP and/or a member company.
(7) “Outreach Required” means RMI member companies need to contact entity to encourage their participation in audit program.
(8) “RMI Due Diligence Review – Unable to Proceed” means the smelter or refiner has not met the thresholds for the Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted.
| Mineral | Smelter / Refiner CID |
Smelter / Refiner Name | Smelter / Refiner Location | RMI Audit Status |
| Gold | CID000015 | Advanced Chemical Company | United States of America | Conformant |
| Gold | CID000019 | Aida Chemical Industries Co., Ltd. | Japan | Conformant |
| Gold | CID000035 | Allgemeine Gold-und Silberscheideanstalt A.G. | Germany | Conformant |
| Gold | CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Conformant |
| Gold | CID000058 | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | Conformant |
| Gold | CID000077 | Argor-Heraeus S.A. | Switzerland | Conformant |
| Gold | CID000082 | Asahi Pretec Corp. | Japan | Conformant |
| Gold | CID000090 | Asaka Riken Co., Ltd. | Japan | Conformant |
| Gold | CID000103 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | Outreach Required |
| Gold | CID000113 | Aurubis AG | Germany | Conformant |
| old | CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Conformant |
| Gold | CID000157 | Boliden AB | Sweden | Conformant |
| Gold | CID000176 | C. Hafner GmbH + Co. KG | Germany | Conformant |
| Gold | CID000180 | Caridad | Mexico | Outreach Required |
| Gold | CID000185 | CCR Refinery - Glencore Canada Corporation | Canada | Conformant |
10
| Gold | CID000189 | Cendres + Metaux S.A. | Switzerland | Conformant |
| Gold | CID000197 | Yunnan Copper Industry Co., Ltd. | China | Outreach Required |
| Gold | CID000233 | Chimet S.p.A. | Italy | Conformant |
| Gold | CID000264 | Chugai Mining | Japan | Conformant |
| Gold | CID000343 | Daye Non-Ferrous Metals Mining Ltd. | China | In Communication |
| Gold | CID000359 | DSC (Do Sung Corporation) | Korea, Republic of | Conformant |
| Gold | CID000401 | Dowa | Japan | Conformant |
| Gold | CID000425 | Eco-System Recycling Co., Ltd. East Plant | Japan | Conformant |
| Gold | CID000493 | OJSC Novosibirsk Refinery | Russian Federation | Non-Conformant |
| Gold | CID000522 | Refinery of Seemine Gold Co., Ltd. | China | Outreach Required |
| Gold | CID000651 | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China | Outreach Required |
| Gold | CID000671 | Hangzhou Fuchunjiang Smelting Co., Ltd. | China | Outreach Required |
| Gold | CID000689 | LT Metal Ltd. | Korea, Republic of | Conformant |
| Gold | CID000694 | Heimerle + Meule GmbH | Germany | Conformant |
| Gold | CID000707 | Heraeus Metals Hong Kong Ltd. | China | Conformant |
| Gold | CID000711 | Heraeus Precious Metals GmbH & Co. KG | Germany | Conformant |
| Gold | CID000767 | Hunan Chenzhou Mining Co., Ltd. | China | Outreach Required |
| Gold | CID000773 | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China | Outreach Required |
| Gold | CID000778 | HwaSeong CJ CO., LTD. | Korea, Republic of | Communication Suspended - Not Interested |
| Gold | CID000801 | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China | Conformant |
| Gold | CID000807 | Ishifuku Metal Industry Co., Ltd. | Japan | Conformant |
| Gold | CID000814 | Istanbul Gold Refinery | Turkey | Conformant |
| Gold | CID000823 | Japan Mint | Japan | Conformant |
| Gold | CID000855 | Jiangxi Copper Co., Ltd. | China | Conformant |
| Gold | CID000920 | Asahi Refining USA Inc. | United States of America | Conformant |
| Gold | CID000924 | Asahi Refining Canada Ltd. | Canada | Conformant |
| Gold | CID000927 | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID000929 | JSC Uralelectromed | Russian Federation | Non-Conformant |
| Gold | CID000937 | JX Nippon Mining & Metals Co., Ltd. | Japan | Conformant |
| Gold | CID000956 | Kazakhmys Smelting LLC | Kazakhstan | In Communication |
| Gold | CID000957 | Kazzinc | Kazakhstan | Conformant |
| Gold | CID000969 | Kennecott Utah Copper LLC | United States of America | Conformant |
| Gold | CID000981 | Kojima Chemicals Co., Ltd. | Japan | Conformant |
| Gold | CID001029 | Kyrgyzaltyn JSC | Kyrgyzstan | Non-Conformant |
| Gold | CID001032 | L'azurde Company For Jewelry | Saudi Arabia | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID001056 | Lingbao Gold Co., Ltd. | China | Outreach Required |
11
| Gold | CID001058 | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China | Outreach Required |
| Gold | CID001078 | LS-NIKKO Copper Inc. | Korea, Republic of | Conformant |
| Gold | CID001093 | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China | Outreach Required |
| Gold | CID001113 | Materion | United States of America | Conformant |
| Gold | CID001119 | Matsuda Sangyo Co., Ltd. | Japan | Conformant |
| Gold | CID001147 | Metalor Technologies (Suzhou) Ltd. | China | Conformant |
| Gold | CID001149 | Metalor Technologies (Hong Kong) Ltd. | China | Conformant |
| Gold | CID001152 | Metalor Technologies (Singapore) Pte., Ltd. | Singapore | Conformant |
| Gold | CID001153 | Metalor Technologies S.A. | Switzerland | Conformant |
| Gold | CID001157 | Metalor USA Refining Corporation | United States of America | Conformant |
| Gold | CID001161 | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico | Conformant |
| Gold | CID001188 | Mitsubishi Materials Corporation | Japan | Conformant |
| Gold | CID001193 | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
| Gold | CID001204 | Moscow Special Alloys Processing Plant | Russian Federation | Non-Conformant |
| Gold | CID001220 | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey | Conformant |
| Gold | CID001236 | Navoi Mining and Metallurgical Combinat | Uzbekistan | Conformant |
| Gold | CID001259 | Nihon Material Co., Ltd. | Japan | Conformant |
| Gold | CID001325 | Ohura Precious Metal Industry Co., Ltd. | Japan | Conformant |
| Gold | CID001326 | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation | Non-Conformant |
| Gold | CID001352 | PAMP S.A. | Switzerland | Conformant |
| Gold | CID001362 | Penglai Penggang Gold Industry Co., Ltd. | China | Outreach Required |
| Gold | CID001386 | Prioksky Plant of Non-Ferrous Metals | Russian Federation | Non-Conformant |
| Gold | CID001397 | PT Aneka Tambang (Persero) Tbk | Indonesia | Conformant |
| Gold | CID001498 | PX Precinox S.A. | Switzerland | Conformant |
| Gold | CID001512 | Rand Refinery (Pty) Ltd. | South Africa | Conformant |
| Gold | CID001534 | Royal Canadian Mint | Canada | Conformant |
| Gold | CID001546 | Sabin Metal Corp. | United States of America | Communication Suspended - Not Interested |
| Gold | CID001555 | Samduck Precious Metals | Korea, Republic of | Conformant |
| Gold | CID001562 | Samwon Metals Corp. | Korea, Republic of | Communication Suspended - Not Interested |
| Gold | CID001585 | SEMPSA Joyeria Plateria S.A. | Spain | Conformant |
| Gold | CID001619 | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | China | Outreach Required |
| Gold | CID001622 | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China | Conformant |
| Gold | CID001736 | Sichuan Tianze Precious Metals Co., Ltd. | China | Conformant |
| Gold | CID001756 | SOE Shyolkovsky Factory of Secondary Precious Metals | Russian Federation | Non-Conformant |
| Gold | CID001761 | Solar Applied Materials Technology Corp. | Taiwan, Province of China | Conformant |
12
| Gold | CID001798 | Sumitomo Metal Mining Co., Ltd. | Japan | Conformant |
| Gold | CID001810 | Super Dragon Technology Co., Ltd. | China | Outreach Required |
| Gold | CID001875 | Tanaka Kikinzoku Kogyo K.K. | Japan | Conformant |
| Gold | CID001909 | Great Wall Precious Metals Co., Ltd. of CBPM | China | Outreach Required |
| Gold | CID001916 | The Refinery of Shandong Gold Mining Co., Ltd. | China | Conformant |
| Gold | CID001938 | Tokuriki Honten Co., Ltd. | Japan | Conformant |
| Gold | CID001947 | Tongling Nonferrous Metals Group Co., Ltd. | China | Outreach Required |
| Gold | CID001955 | Torecom | Korea, Republic of | Conformant |
| Gold | CID001980 | Umicore S.A. Business Unit Precious Metals Refining | Belgium | Conformant |
| Gold | CID001993 | United Precious Metal Refining, Inc. | United States of America | Conformant |
| Gold | CID002003 | Valcambi S.A. | Switzerland | Conformant |
| Gold | CID002030 | Western Australian Mint (T/a The Perth Mint) | Australia | Conformant |
| Gold | CID002100 | Yamakin Co., Ltd. | Japan | Conformant |
| Gold | CID002129 | Yokohama Metal Co., Ltd. | Japan | Conformant |
| Gold | CID002224 | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China | Conformant |
| Gold | CID002243 | Gold Refinery of Zijin Mining Group Co., Ltd. | China | Conformant |
| Gold | CID002282 | Morris and Watson | New Zealand | In Communication |
| Gold | CID002290 | SAFINA A.S. | Czechia | Conformant |
| Gold | CID002312 | Guangdong Jinding Gold Limited | China | Outreach Required |
| Gold | CID002314 | Umicore Precious Metals Thailand | Thailand | Conformant |
| Gold | CID002459 | Geib Refining Corporation | United States of America | Conformant |
| Gold | CID002509 | MMTC-PAMP India Pvt., Ltd. | India | Conformant |
| Gold | CID002511 | KGHM Polska Miedz Spolka Akcyjna | Poland | Conformant |
| Gold | CID002515 | Fidelity Printers and Refiners Ltd. | Zimbabwe | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID002516 | Singway Technology Co., Ltd. | Taiwan, Province of China | Conformant |
| Gold | CID002525 | Shandong Humon Smelting Co., Ltd. | China | Outreach Required |
| Gold | CID002527 | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China | Outreach Required |
| Gold | CID002560 | Al Etihad Gold Refinery DMCC | United Arab Emirates | Conformant |
| Gold | CID002561 | Emirates Gold DMCC | United Arab Emirates | Conformant |
| Gold | CID002562 | International Precious Metal Refiners | United Arab Emirates | In Communication |
| Gold | CID002563 | Kaloti Precious Metals | United Arab Emirates | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID002567 | Sudan Gold Refinery | Sudan | Outreach Required |
| Gold | CID002580 | T.C.A S.p.A | Italy | Conformant |
| Gold | CID002582 | REMONDIS PMR B.V. | Netherlands | Conformant |
| Gold | CID002584 | Fujairah Gold FZC | United Arab Emirates | Outreach Required |
13
| Gold | CID002587 | Industrial Refining Company | Belgium | Non-Conformant |
| Gold | CID002588 | Shirpur Gold Refinery Ltd. | India | Outreach Required |
| Gold | CID002605 | Korea Zinc Co., Ltd. | Korea, Republic Of | Conformant |
| Gold | CID002606 | Marsam Metals | Brazil | Conformant |
| Gold | CID002615 | TOO Tau-Ken-Altyn | Kazakhstan | Conformant |
| Gold | CID002708 | Abington Reldan Metals, LLC | United States of America | Non-Conformant |
| Gold | CID002761 | SAAMP | France | Conformant |
| Gold | CID002762 | L'Orfebre S.A. | Andorra | Conformant |
| Gold | CID002763 | 8853 S.p.A. | Italy | Conformant |
| Gold | CID002765 | Italpreziosi | Italy | Conformant |
| Gold | CID002778 | WIELAND Edelmetalle GmbH | Germany | Conformant |
| Gold | CID002779 | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | Conformant |
| Gold | CID002850 | AU Traders and Refiners | South Africa | Non-Conformant |
| Gold | CID002852 | GCC Gujrat Gold Centre Pvt. Ltd. | India | Active |
| Gold | CID002853 | Sai Refinery | India | Outreach Required |
| Gold | CID002857 | Modeltech Sdn Bhd | Malaysia | Non-Conformant |
| Gold | CID002863 | Bangalore Refinery | India | Conformant |
| Gold | CID002865 | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | Outreach Required |
| Gold | CID002867 | Degussa Sonne / Mond Goldhandel GmbH | Germany | Outreach Required |
| Gold | CID002872 | Pease & Curren | United States of America | Communication Suspended - Not Interested |
| Gold | CID002893 | JALAN & Company | India | Outreach Required |
| Gold | CID002918 | SungEel HiMetal Co., Ltd. | Korea, Republic Of | Conformant |
| Gold | CID002919 | Planta Recuperadora de Metales SpA | Chile | Conformant |
| Gold | CID002973 | Safimet S.p.A | Italy | Conformant |
| Gold | CID003153 | State Research Institute Center for Physical Sciences and Technology | Lithuania | Outreach Required |
| Gold | CID003185 | African Gold Refinery | Uganda | Outreach Required |
| Gold | CID003186 | Gold Coast Refinery | Ghana | Outreach Required |
| Gold | CID003189 | NH Recytech Company | Korea, Republic of | Conformant |
| Gold | CID003324 | QG Refining, LLC | United States of America | Outreach Required |
| Gold | CID003348 | Dijllah Gold Refinery FZC | United Arab Emirates | Outreach Required |
| Gold | CID003382 | CGR Metalloys Pvt Ltd. | India | Outreach Required |
| Gold | CID003383 | Sovereign Metals | India | Outreach Required |
| Gold | CID003421 | C.I Metales Procesados Industriales SAS | Colombia | Active |
| Gold | CID003424 | Eco-System Recycling Co., Ltd. North Plant | Japan | Conformant |
| Gold | CID003425 | Eco-System Recycling Co., Ltd. West Plant | Japan | Conformant |
| Gold | CID003461 | Augmont Enterprises Private Limited | India | Active |
| Gold | CID003463 | Kundan Care Products Ltd. | India | In Communication |
| Gold | CID003487 | Emerald Jewel Industry India Limited (Unit 1) | India | In Communication |
14
| Gold | CID003488 | Emerald Jewel Industry India Limited (Unit 2) | India | In Communication |
| Gold | CID003489 | Emerald Jewel Industry India Limited (Unit 3) | India | In Communication |
| Gold | CID003490 | Emerald Jewel Industry India Limited (Unit 4) | India | In Communication |
| Gold | CID003497 | K.A. Rasmussen | Norway | Outreach Required |
| Gold | CID003500 | Alexy Metals | United States of America | Active |
| Gold | CID003529 | Sancus ZFS (L’Orfebre, SA) | Colombia | Active |
| Gold | CID003540 | Sellem Industries Ltd. | Mauritania | Communication Suspended - Not Interested |
| Gold | CID003548 | MD Overseas | India | In Communication |
| Gold | CID003557 | Metallix Refining Inc. | United States of America | In Communication |
| Gold | CID003575 | Metal Concentrators SA (Pty) Ltd. | South Africa | Conformant |
| Gold | CID003615 | WEEEREFINING | France | Active |
| Gold | CID003617 | Value Trading | Belgium | In Communication |
| Tantalum | CID000211 | Changsha South Tantalum Niobium Co., Ltd. | China | Conformant |
| Tantalum | CID000460 | F&X Electro-Materials Ltd. | China | Conformant |
| Tantalum | CID000616 | Guangdong Zhiyuan New Material Co., Ltd. | China | Conformant |
| Tantalum | CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conformant |
| Tantalum | CID000917 | Jiujiang Tanbre Co., Ltd. | China | Conformant |
| Tantalum | CID001076 | LSM Brasil S.A. | Brazil | Conformant |
| Tantalum | CID001163 | Metallurgical Products India Pvt., Ltd. | India | Conformant |
| Tantalum | CID001175 | Mineracao Taboca S.A. | Brazil | Conformant |
| Tantalum | CID001192 | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
| Tantalum | CID001200 | NPM Silmet AS | Estonia | Conformant |
| Tantalum | CID001277 | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conformant |
| Tantalum | CID001508 | QuantumClean | United States of America | Conformant |
| Tantalum | CID001522 | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | CID001769 | Solikamsk Magnesium Works OAO | Russian Federation | Conformant |
| Tantalum | CID001869 | Taki Chemical Co., Ltd. | Japan | Conformant |
| Tantalum | CID001891 | Telex Metals | United States of America | Conformant |
| Tantalum | CID001969 | Ulba Metallurgical Plant JSC | Kazakhstan | Conformant |
| Tantalum | CID002492 | Hengyang King Xing Lifeng New Materials Co., Ltd. | China | Conformant |
| Tantalum | CID002504 | D Block Metals, LLC | United States of America | Conformant |
| Tantalum | CID002505 | FIR Metals & Resource Ltd. | China | Conformant |
| Tantalum | CID002506 | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China | Conformant |
| Tantalum | CID002508 | XinXing HaoRong Electronic Material Co., Ltd. | China | Conformant |
| Tantalum | CID002512 | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China | Conformant |
15
| Tantalum | CID002539 | KEMET Blue Metals | Mexico | Conformant |
| Tantalum | CID002544 | H.C. Starck Co., Ltd. | Thailand | Conformant |
| Tantalum | CID002545 | H.C. Starck Tantalum and Niobium GmbH | Germany | Conformant |
| Tantalum | CID002547 | H.C. Starck Hermsdorf GmbH | Germany | Conformant |
| Tantalum | CID002548 | H.C. Starck Inc. | United States of America | Conformant |
| Tantalum | CID002549 | H.C. Starck Ltd. | Japan | Conformant |
| Tantalum | CID002550 | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant |
| Tantalum | CID002557 | Global Advanced Metals Boyertown | United States of America | Conformant |
| Tantalum | CID002558 | Global Advanced Metals Aizu | Japan | Conformant |
| Tantalum | CID002707 | Resind Industria e Comercio Ltda. | Brazil | Conformant |
| Tantalum | CID002842 | Jiangxi Tuohong New Raw Material | China | Conformant |
| Tantalum | CID003583 | Yancheng Jinye New Material Technology Co., Ltd. | China | Conformant |
| Tin | CID000228 | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China | Conformant |
| Tin | CID000292 | Alpha | United States of America | Conformant |
| Tin | CID000309 | PT Aries Kencana Sejahtera | Indonesia | Active |
| Tin | CID000402 | Dowa | Japan | Conformant |
| Tin | CID000438 | EM Vinto | Bolivia (Plurinational State of) | Conformant |
| Tin | CID000448 | Estanho de Rondonia S.A. | Brazil | Conformant |
| Tin | CID000468 | Fenix Metals | Poland | Conformant |
| Tin | CID000538 | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China | Conformant |
| Tin | CID000555 | Gejiu Zili Mining And Metallurgy Co., Ltd. | China | Conformant |
| Tin | CID000942 | Gejiu Kai Meng Industry and Trade LLC | China | Non-Conformant |
| Tin | CID001070 | China Tin Group Co., Ltd. | China | Conformant |
| Tin | CID001105 | Malaysia Smelting Corporation (MSC) | Malaysia | Conformant |
| Tin | CID001142 | Metallic Resources, Inc. | United States of America | Conformant |
| Tin | CID001173 | Mineracao Taboca S.A. | Brazil | Conformant |
| Tin | CID001182 | Minsur | Peru | Conformant |
| Tin | CID001191 | Mitsubishi Materials Corporation | Japan | Conformant |
| Tin | CID001231 | Jiangxi New Nanshan Technology Ltd. | China | Conformant |
| Tin | CID001305 | Novosibirsk Processing Plant Ltd. | Russian Federation | Conformant |
| Tin | CID001314 | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand | Conformant |
| Tin | CID001337 | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State of) | Conformant |
| Tin | CID001399 | PT Artha Cipta Langgeng | Indonesia | Conformant |
| Tin | CID001402 | PT Babel Inti Perkasa | Indonesia | Conformant |
| Tin | CID001406 | PT Babel Surya Alam Lestari | Indonesia | Conformant |
| Tin | CID001421 | PT Belitung Industri Sejahtera | Indonesia | Outreach Required |
| Tin | CID001428 | PT Bukit Timah | Indonesia | Conformant |
| Tin | CID001453 | PT Mitra Stania Prima | Indonesia | Conformant |
| Tin | CID001457 | PT Panca Mega Persada | Indonesia | Outreach Required |
16
| Tin | CID001458 | PT Prima Timah Utama | Indonesia | Conformant |
| Tin | CID001460 | PT Refined Bangka Tin | Indonesia | Conformant |
| Tin | CID001463 | PT Sariwiguna Binasentosa | Indonesia | Conformant |
| Tin | CID001468 | PT Stanindo Inti Perkasa | Indonesia | Conformant |
| Tin | CID001477 | PT Timah Tbk Kundur | Indonesia | Conformant |
| Tin | CID001482 | PT Timah Tbk Mentok | Indonesia | Conformant |
| Tin | CID001486 | PT Timah Nusantara | Indonesia | Active |
| Tin | CID001490 | PT Tinindo Inter Nusa | Indonesia | Conformant |
| Tin | CID001493 | PT Tommy Utama | Indonesia | In Communication |
| Tin | CID001539 | Rui Da Hung | Taiwan, Province of China | Conformant |
| Tin | CID001758 | Soft Metais Ltda. | Brazil | Conformant |
| Tin | CID001898 | Thaisarco | Thailand | Conformant |
| Tin | CID001908 | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Conformant |
| Tin | CID002015 | VQB Mineral and Trading Group JSC | Viet Nam | Outreach Required |
| Tin | CID002036 | White Solder Metalurgia e Mineracao Ltda. | Brazil | Conformant |
| Tin | CID002158 | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China | Conformant |
| Tin | CID002180 | Yunnan Tin Company Limited | China | Conformant |
| Tin | CID002455 | CV Venus Inti Perkasa | Indonesia | Active |
| Tin | CID002468 | Magnu's Minerais Metais e Ligas Ltda. | Brazil | Conformant |
| Tin | CID002478 | PT Tirus Putra Mandiri | Indonesia | Outreach Required |
| Tin | CID002500 | Melt Metais e Ligas S.A. | Brazil | Outreach Required |
| Tin | CID002503 | PT ATD Makmur Mandiri Jaya | Indonesia | Conformant |
| Tin | CID002517 | O.M. Manufacturing Philippines, Inc. | Philippines | Conformant |
| Tin | CID002572 | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Viet Nam | Non-Conformant |
| Tin | CID002573 | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Viet Nam | Outreach Required |
| Tin | CID002574 | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Viet Nam | Outreach Required |
| Tin | CID002696 | PT Cipta Persada Mulia | Indonesia | Conformant |
| Tin | CID002703 | An Vinh Joint Stock Mineral Processing Company | Viet Nam | Outreach Required |
| Tin | CID002706 | Resind Industria e Comercio Ltda. | Brazil | Conformant |
| Tin | CID002756 | Super Ligas | Brazil | Active |
| Tin | CID002773 | Metallo Belgium N.V. | Belgium | Conformant |
| Tin | CID002774 | Metallo Spain S.L.U. | Spain | Conformant |
| Tin | CID002816 | PT Sukses Inti Makmur | Indonesia | Active |
| Tin | CID002834 | Thai Nguyen Mining and Metallurgy Co., Ltd. | Viet Nam | Conformant |
| Tin | CID002835 | PT Menara Cipta Mulia | Indonesia | Conformant |
| Tin | CID002858 | Modeltech Sdn Bhd | Malaysia | Non-Conformant |
| Tin | CID003116 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | Conformant |
17
| Tin | CID003190 | Chifeng Dajingzi Tin Industry Co., Ltd. | China | Conformant |
| Tin | CID003205 | PT Bangka Serumpun | Indonesia | Conformant |
| Tin | CID003208 | Pongpipat Company Limited | Myanmar | Outreach Required |
| Tin | CID003325 | Tin Technology & Refining | United States of America | Conformant |
| Tin | CID003356 | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China | Non-Conformant |
| Tin | CID003379 | Ma'anshan Weitai Tin Co., Ltd. | China | Conformant |
| Tin | CID003380 | PT Masbro Alam Stania | Indonesia | Active |
| Tin | CID003381 | PT Rajawali Rimba Perkasa | Indonesia | Conformant |
| Tin | CID003387 | Luna Smelter, Ltd. | Rwanda | Conformant |
| Tin | CID003397 | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | Non-Conformant |
| Tin | CID003409 | Precious Minerals and Smelting Limited | India | Non-Conformant |
| Tin | CID003410 | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | Outreach Required |
| Tin | CID003449 | PT Mitra Sukses Globalindo | Indonesia | Active |
| Tin | CID003486 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | Active |
| Tin | CID003524 | CRM Synergies | Spain | Conformant |
| Tin | CID003582 | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | Conformant |
| Tungsten | CID000004 | A.L.M.T. Corp. | Japan | Conformant |
| Tungsten | CID000105 | Kennametal Huntsville | United States of America | Conformant |
| Tungsten | CID000218 | Guangdong Xianglu Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID000258 | Chongyi Zhangyuan Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID000281 | CNMC (Guangxi) PGMA Co., Ltd. | China | Outreach Required |
| Tungsten | CID000568 | Global Tungsten & Powders Corp. | United States of America | Conformant |
| Tungsten | CID000766 | Hunan Chenzhou Mining Co., Ltd. | China | Conformant |
| Tungsten | CID000769 | Hunan Chunchang Nonferrous Metals Co., Ltd. | China | Conformant |
| Tungsten | CID000825 | Japan New Metals Co., Ltd. | Japan | Conformant |
| Tungsten | CID000875 | Ganzhou Huaxing Tungsten Products Co., Ltd. | China | Conformant |
| Tungsten | CID000966 | Kennametal Fallon | United States of America | Conformant |
| Tungsten | CID002044 | Wolfram Bergbau und Hutten AG | Austria | Conformant |
| Tungsten | CID002082 | Xiamen Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID002313 | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China | Communication Suspended - Not Interested |
| Tungsten | CID002315 | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China | Conformant |
| Tungsten | CID002316 | Jiangxi Yaosheng Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID002317 | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | China | Conformant |
| Tungsten | CID002318 | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | China | Conformant |
| Tungsten | CID002319 | Malipo Haiyu Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID002320 | Xiamen Tungsten (H.C.) Co., Ltd. | China | Conformant |
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| Tungsten | CID002321 | Jiangxi Gan Bei Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID002494 | Ganzhou Seadragon W & Mo Co., Ltd. | China | Conformant |
| Tungsten | CID002502 | Asia Tungsten Products Vietnam Ltd. | Viet Nam | Conformant |
| Tungsten | CID002513 | Chenzhou Diamond Tungsten Products Co., Ltd. | China | Conformant |
| Tungsten | CID002541 | H.C. Starck Tungsten GmbH | Germany | Conformant |
| Tungsten | CID002542 | H.C. Starck Smelting GmbH & Co. KG | Germany | Conformant |
| Tungsten | CID002543 | Masan Tungsten Chemical LLC (MTC) | Viet Nam | Conformant |
| Tungsten | CID002551 | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China | Conformant |
| Tungsten | CID002589 | Niagara Refining LLC | United States of America | Conformant |
| Tungsten | CID002641 | China Molybdenum Co., Ltd. | China | Conformant |
| Tungsten | CID002645 | Ganzhou Haichuang Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID002649 | Hydrometallurg, JSC | Russian Federation | Conformant |
| Tungsten | CID002724 | Unecha Refractory metals plant | Russian Federation | Conformant |
| Tungsten | CID002827 | Philippine Chuangxin Industrial Co., Inc. | Philippines | Conformant |
| Tungsten | CID002830 | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China | Conformant |
| Tungsten | CID002833 | ACL Metais Eireli | Brazil | Conformant |
| Tungsten | CID002845 | Moliren Ltd. | Russian Federation | Conformant |
| Tungsten | CID003388 | KGETS Co., Ltd. | Korea, Republic Of | Conformant |
| Tungsten | CID003401 | Fujian Ganmin RareMetal Co., Ltd. | China | Conformant |
| Tungsten | CID003407 | Lianyou Metals Co., Ltd. | Taiwan, Province of China | Conformant |
| Tungsten | CID003408 | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | Conformant |
| Tungsten | CID003416 | NPP Tyazhmetprom LLC | Russian Federation | Active |
| Tungsten | CID003417 | GEM Co., Ltd. | China | Conformant |
| Tungsten | CID003427 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | Active |
| Tungsten | CID003468 | Cronimet Brasil Ltda | Brazil | Conformant |
| Tungsten | CID003553 | Artek LLC | Russian Federation | Outreach Required |
| Tungsten | CID003609 | Fujian Xinlu Tungsten | China | Conformant |
| Tungsten | CID003612 | OOO “Technolom” 2 | Russian Federation | Active |
| Tungsten | CID003614 | OOO “Technolom” 1 | Russian Federation | Active |
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APPENDIX B
Countries of Origin
Avnet utilized data its Suppliers provided on their CMRTs for the 2021 Program and relied on information provided by RBA’s RMI due diligence of smelters and refiners regarding the countries of origin and mines or locations of origin to prepare the below list. The list: (1) may not include all of the countries which ultimately sourced the CMs in the Covered Products and (2) may include countries which did not ultimately source CMs contained in the Covered Products.
| Country of Origin (Material) | |||
| Afghanistan | Dominica | Lithuania | Singapore |
| Åland Islands | Dominican Republic | Luxembourg | Slovakia |
| Albania | Ecuador | Madagascar | Slovenia |
| American Samoa | Egypt | Malaysia | South Africa |
| Andorra | Eritrea | Mali | South Sudan |
| Angola | Estonia | Mauritania | Spain |
| Argentina | Ethiopia | Mexico | Sudan |
| Armenia | Finland | Mongolia | Suriname |
| Australia | France | Morocco | Sweden |
| Austria | Germany | Mozambique | Switzerland |
| Belarus | Ghana | Myanmar | Taiwan |
| Belgium | Guinea | Namibia | Tajikistan |
| Bermuda | Guyana | Netherlands | Tanzania |
| Bolivia (Plurinational State of) | Hong Kong | New Zealand | Thailand |
| Brazil | Hungary | Niger | Turkey |
| Bulgaria | India | Nigeria | Uganda |
| Burundi | Indonesia | Panama | United Arab Emirates |
| Cambodia | Ireland | Papua New Guinea | United Kingdom |
| Canada | Israel | Peru | United States |
| Central African Republic | Italy | Philippines | Uzbekistan |
| Chile | Japan | Poland | Viet Nam |
| China | Kazakhstan | Portugal | Zambia |
| Colombia | Kenya | Russian Federation | Zimbabwe |
| Congo | Korea | Rwanda | |
| Democratic Republic of Congo | Kyrgyzstan | Saudi Arabia | |
| Djibouti | Liberia | Sierra Leone | |
20