UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
AVNET, INC.
(Exact name of registrant as specified in its charter)
| New York | 1-4224 | 11-1890605 | ||
| (State or other jurisdiction | (Commission File Number) | (IRS Employer | ||
| of incorporation or organization) | Identification No.) |
| 2211 South 47th Street, Phoenix, Arizona | 85034 | |
| (Address of principal executive offices) | (Zip Code) |
Darrel S. Jackson
Corporate Secretary
(480) 643-2000
(Name and telephone number, including area code,
of the person to contact in connection with 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, 2023. |
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, 2023, 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, 2023. |
| 2 |
SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.
| Date: May 24, 2024 | By: | /s/ Kenneth A. Jacobson |
| Name: Kenneth A. Jacobson | ||
| Title: Chief Financial officer | ||
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Exhibit 1.01
CONFLICT MINERALS REPORT
For the Reporting Period from January 1 to December 31, 2023
Introduction
This Conflict Minerals Report of Avnet, Inc. for the calendar year 2023 (“Report”) is filed May 24, 2024, as an exhibit to the Company’s Form SD, as required under Rule 13p-1 of the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”). The Report is posted on the Company’s website at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals. Other information available through the Company’s website is not part of this Report.
References to “the Company,” “Avnet,” “we,” “our,” or “us” means Avnet, Inc. and its subsidiaries, except where the context otherwise requires.
Applicability of the Conflict Minerals Rule to Avnet
Avnet 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 electromechanical), and other integrated and embedded components; and distributes a comprehensive portfolio of kits, tools, industrial automation components, and test and measurement products. It also provides embedded solutions, such as technical design, integration and assembly of 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 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”). CMs are used in many electronic components and computer products. 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 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 imply 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.
Avnet’s revenues for 2023 were largely from distribution and other services that were not in-scope for purposes of compliance with the Conflict Minerals Rule. However, during 2023, it manufactured or contracted to manufacture certain products that include CMs (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.
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.
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Avnet is a downstream consumer of CMs. It does not purchase the 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, including through its engagement of Assent, a third-party service provider that is a member of RBA’s Responsible Minerals Initiative (“RMI”). In addition, the Company has actively engaged with its customers and suppliers for several years with respect to the use of CMs. It has also 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.
This policy is available at https://www.avnet.com/wps/portal/us/about-avnet/human-rights/conflict-minerals.
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Conflict Minerals Program
Design of Conflict Minerals Program
Avnet’s 2023 Conflict Minerals Program (“2023 Program”) utilized the internationally recognized framework to identify the country of origin and chain of custody of the CMs. The framework (which includes supplements for gold, tin, tantalum, and tungsten) is called The Organization for Economic Co-Operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Framework”).
Avnet’s supply chain with respect to the CMs in our Covered Products is highly complex. We do not purchase CMs directly from any mine, refiner, or smelter 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 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 2023 contained CMs necessary to the functionality or production of those products:
| · | Semi-conductor electronic devices designed and contracted to be manufactured by Avnet per customer specifications. |
| · | Electronic boards, electronic devices, display solutions, and Human-Machine Interface (HMI) solutions manufactured or contracted to be manufactured by Avnet Embedded GmbH. |
| · | Control boards and HMIs contracted to be manufactured. |
| · | Server based products integrated from customer designed or off-the-shelf components by Avnet Integrated. |
| · | Design kits and modules manufactured or contracted to be manufactured by Avnet. |
| · | Development boards manufactured or contracted to be manufactured by EBV Elektronik. |
| · | Development boards and accessories contracted to be manufactured by Avnet. |
| · | Printed circuit board assembly (PCBA) designed by customer and contracted to be manufactured by Farnell. |
| · | PCBA and high-level integration of customer products. |
| · | Avnet Guardian products manufactured or contracted to be manufactured by Avnet. |
| · | Cables and electromechanical assembled products manufactured or contracted to be manufactured by Avnet. |
Pursuant to the Conflict Minerals Rule, Covered Products do not include products (i) that were not entered into the stream of commerce in 2023, and (ii) that were manufactured or contracted to be manufactured by entities that Avnet acquired after April 2023.
Reasonable Country of Origin Inquiry
Pursuant to the Conflict Minerals Rule, Avnet conducted a RCOI on the source and chain of custody of CMs in its Covered Products to determine whether any they 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 2023 RCOI included 484 suppliers that Avnet identified as possibly providing it with components, parts or products that contained CMs for its Covered Products. These suppliers identified smelters and refiners that may have processed the 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”), as well as 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 (validated facilities are listed in Appendix A) and to determine the countries from where such validated facilities may have obtained CMs (countries are listed in Appendix B). For this process, Avnet used the data its Suppliers provided on their CMRTs version 6.2 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, 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 2023 RCOI, Avnet contacted suppliers via Assent Sustainability Manager (“ASM”), 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. ASM’s functionality 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 ASM.
Avnet requested that all suppliers complete a CMRT. On Avnet’s behalf, Assent offered training and educational resources to Suppliers to guide them on best practices, completing a CMRT, and using the ASM platform. Avnet monitored and tracked all communications in ASM for future reporting and transparency. Avnet may directly follow-up with a supplier that does not respond after three requests through ASM.
Supplier CMRTs undergo an automated data validation process to increase the completeness and accuracy of submissions and to identify any contradictory answers. 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.
Supplier CMRTs are accepted and classified as either valid or invalid. If a supplier’s CMRT is invalid, the supplier receives feedback and guidance on how to correct the validation errors and is asked to 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 2023 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.
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 made up of senior management and is responsible for ensuring that the program meets regulatory requirements and enterprise goals and provides direction to the working team. The working team is responsible for the day-to-day implementation of the program, diligence efforts, and risk mitigation strategy. It also informs the governance team about the results of the due diligence and risk mitigation efforts. |
| · | Avnet uses a third-party service provider, Assent, to assist with collecting and evaluating supply chain information, identifying potential risks, and developing additional due diligence steps. Please see “Conflict Minerals Program – Reasonable Country of Origin Inquiry” for more information on the use of Assent and its software platform ASM. Avnet also leverages Assent’s managed services to work with dedicated program specialists who support Avnet’s CM program and provide Avnet updates on program status. |
| · | Avnet has a Responsible Minerals Sourcing Policy, as discussed earlier in this Report. Pursuant to this policy, Avnet expects its suppliers to source CMs only from responsible sources and to provide proper verification of the country of origin and source of the materials used in the products they supply to Avnet. Suppliers either receive a copy of the policy or are notified of this policy. In addition, the policy is posted on Avnet’s website. This policy is reviewed annually by the governance team. |
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| · | Avnet’s Global Supplier Quality Handbook further discloses its expectations for suppliers, including an expectation that suppliers only source materials from environmentally and socially responsible suppliers. |
| · | Avnet seeks to include CM related provisions in new or amended supplier agreements with respect to the Covered Products. Its current form of supplier agreement contains a CM provision that requires a supplier to warrant that any products it supplies containing CMs either does not finance or benefit armed groups in the Covered Countries or are from recycled or scrap sources. |
| · | Avnet uses the current CMRT version developed by RMI to identify smelters and refiners in its supply chain. The CMRT requires Suppliers to provide information concerning the usage and source of CMs in their components, parts, and products, as well as information concerning their related compliance efforts, including whether they have a policy on conflict-free sourcing and require their own suppliers to source CMs from responsible sources. |
| · | By using Assent, Avnet provides its suppliers access to a free platform to upload their CMRTs, help desk support, educational resources on how to properly complete and submit a CMRT, and other multilingual resources. |
| · | Employees, vendors, suppliers, customers and any third-party can confidentially report concerns regarding Avnet’s business operations, including compliance with the Responsible Minerals Sourcing Policy, through the Ethics Alertline, via phone or internet. Violations or grievances at the industry level can be reported to the RMI directly at http://responsiblemineralsinitiative.org/responsible-minerals-assurance-process/grievance-mechanism/. |
| · | Avnet has a document retention policy to retain CM related documents, including supplier responses to CMRTs and the sources identified within each reporting period, for at least five years. |
2. 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 substantial majority of Avnet’s operations are out of scope of the Conflict Minerals Rule. |
| · | Avnet identifies the active suppliers of materials, components, parts, and products that may contain CMs for the Covered Products, and each supplier is requested to complete the then latest revision of the CMRT. Avnet expects its direct suppliers to survey their suppliers. |
| · | Supplier level risks include non-responsive suppliers. Avnet tracks receipt of Supplier CMRTs. Avnet may directly follow-up with Suppliers that do not respond after three requests through the ASM platform. Follow-up with non-responsive suppliers continued into 2024. |
| · | Supplier level risks include incomplete or invalid submitted CMRTs. Submitted CMRTs go through a data validation process to evaluate responses for plausibility, completion, and consistency to lower the risks associated with supplier CMRT content. To the extent that a CMRT is incomplete or invalid, or other relevant information is not provided by a supplier, follow-up procedures are undertaken to request compliance and to offer feedback, guidance, and educational resources. Follow-up with such suppliers continued into 2024. |
| · | Supplier level risks include weak or undeveloped Supplier CM programs. Based on a supplier’s submitted CMRT, the strength of a supplier’s related compliance efforts, including whether it has a conflict minerals sourcing policy or implements due diligence measures for conflict free sourcing, is evaluated, tracked, and rated as either weak or strong. |
| · | Supplier level risks include supplier CMRTs that are based on company-level information versus Covered Product-level information. Suppliers may have been over-inclusive if their suppliers provide information on a company-level basis and under-inclusive if suppliers experience non-responsive suppliers or incomplete supplier CMRTs. Therefore, the Company is unable to determine if the smelters and refiners listed in Appendix A were all used or is a complete list of smelters and refiners utilized for CMs in the Covered Products. |
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| · | Supplier level risks include suppliers with problematic smelters and refiners in its supply chain. The CMRT data validation process evaluates responses for predetermined red flag indicators defined in the OECD Framework to identify risks in the supply chain posed by smelters and refiners. |
| o | Smelters and refiners identified in the CMRTs are compared against the Smelter Look-up tab of the CMRT and the list of Conformant smelters and refiners and country of origin information published by the RMI to determine if the smelter had been audited against a standard in conformance with the OECD Framework, such as RMAP. |
| o | If a smelter’s due diligence practices have not been audited against the RMAP standard or the smelter is considered non-conformant by RMAP, follow-ups may be conducted with Suppliers reporting those facilities and the facilities are assessed for potential sourcing risks. |
| o | The process uses multiple factors to determine the level of risk that each smelter and refiner poses to the supply chain. Factors include: RMAP audit status, geographic proximity to Conflict-Affected and High Risk Areas, known mineral source country of origin, credible evidence of unethical or conflict sourcing, peer assessments conducted by credible third-party sources, and sanction risks. |
3. 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.” Feedback on Supplier CMRTs is given directly to suppliers and educational resources are provided to assist suppliers in corrective action methods or to improve their internal programs. |
| · | Avnet works with Suppliers on an as-needed basis to assist them with understanding the requirements of the Conflict Minerals Rule. Through Assent, Avnet also offers training and educational resources to suppliers to guide them on best practices, completing a CMRT, and using the ASM platform. |
| · | Avnet participates in Assent’s smelter outreach initiative, where letters are sent twice a year to each smelter and refiner not conformant or not enrolled in RMAP to encourage participation in a cross-recognized industry audit program. The initiative also includes letters to smelters and refiners who are conformant to RMAP to reflect appreciation for their efforts. |
| · | Working team leaders monitor risks and share the CM Program results, risk assessments, and draft Form SD filings with the governance team to ensure transparency within Avnet. |
| · | Avnet’s Responsible Minerals Sourcing Policy publicly announces its expectations that suppliers participate in Avnet’s due diligence process by providing proper verification of the country of origin and source of the materials used in the Covered Products they supply to Avnet. The policy and the Global Supplier Quality Handbook also state that Suppliers are expected to source CMs only from responsible sources. |
| · | Avnet seeks to include CM related provisions in new or amended supplier agreements with respect to the Covered Products and include CM related due diligence in acquisition activities. |
| · | Avnet has processes in place for new product introductions and changes to the bill of materials for the Covered Products to help ensure compliance with the Conflict Minerals Program. |
| · | Employees, vendors, suppliers, customers and any third-party can confidentially report concerns regarding Avnet’s business operations, including compliance with the Responsible Minerals Sourcing Policy, through the Ethics Alertline, via phone or internet. |
4. Carry out independent third-party audit of supply chain due diligence
| · | Avnet is not positioned to conduct direct audits of smelters and refiners’ due diligence practices, as it is a downstream consumer of CMs and is generally many steps removed from smelters and refiners that provide minerals and ores. Instead, it relies on initiatives such as those led by RBA, including RMI, to conduct smelter and refinery due diligence audits. |
5. 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. |
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Results of 2023 Conflict Minerals Program
As a downstream purchaser of components, parts and products that may contain CMs, Avnet’s 2023 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 includes 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. Finally, not all suppliers completed CMRTs or completed CMRTs in full for the 2023 Program.
For the 2023 Program, 484 Suppliers were identified, of which 333 (or 68.8%) submitted a completed CMRT, a decrease from the 2022 program.
| Supplier CMRT Results | |||||||||||||||||||||
| Year of Program | # Suppliers in Scope | # Completed CMRTs | % Completed CMRTs | # Valid CMRTs | % Valid CMRTs | ||||||||||||||||
| 2023 | 484 | 333 | 68.8 | % | 329 | 68.0 | % | ||||||||||||||
| 2022 | 429 | 297 | 69.2 | % | 290 | 67.6 | % | ||||||||||||||
| Strength of Supplier CM Program Results | |||||||||||||||||||||
| Year of 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 | ||||||||||||||||
| 2023 | 333 | 267 | 39 | 306 | 91.9 | % | |||||||||||||||
| 2022 | 297 | 228 | 37 | 265 | 89.2 | % | |||||||||||||||
The 351 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 incomplete or more comprehensive than the smelters and refiners that actually processed the CMs contained in the Covered Products. The below table summarizes the number of such legitimate smelters and refiners that 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.
| Smelter and Refiner Audit Status Results | ||||||||
| RMI Audit Status | Legitimate Smelters and Refiners | |||||||
| RMAP Conformant | 225 | 64.1 | % | |||||
| RMAP Active | 6 | 1.7 | % | |||||
| Non-Conformant | 29 | 8.3 | % | |||||
| Not Enrolled (roll up of the statuses below) | 91 | 25.9 | % | |||||
| Total | 351 | 100.00 | % | |||||
| 7 |
| Not Enrolled subcategories | Count | |||
| Communication Suspended - Not Interested | 6 | |||
| Due Diligence Vetting Process | 0 | |||
| In Communication | 1 | |||
| Outreach Required | 62 | |||
| RMI Due Diligence Review - Unable to Proceed | 22 | |||
The compliance status information provided in the table above is based solely on information made available by RMI, without independent verification by the Company. Following are definitions of certain terms used in the chart:
| · | “Conformant” means that the smelter or refiner has completed the independent annual audit process and been found to be in conformance with the relevant RMAP standard, whereby verified to have conflict-free sources. |
| · | “Active” means that the smelter or refiner is in the process of being independently audited or has committed to begin the audit process but has not yet been determined to be in conformance with the relevant RMAP standard. |
| · | “Non-Conformant” means that the smelter or refiner has been independently assessed but found not to be in conformance with the relevant RMAP standard. |
| · | “Communication Suspended – Not Interested” means the smelter or refiner has strongly communicated a lack of interest in participating in the audit program. |
| · | “Due Diligence Vetting Process” means the smelter or refiner does not meet RMI’s requirements for participation in the audit program according to the Due Diligence Vetting Process. |
| · | “In Communication” means the smelter or refiner is not yet active but is in communications with RMAP and/or a member company. |
| · | “Outreach Required” means RMI member companies need to contact entity to encourage their participation in audit program. |
| · | “RMI Due Diligence Review – Unable to Proceed” means the smelter or refiner has not met the thresholds for the Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted. |
The aggregated list of countries of origin from which the 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 incomplete or more comprehensive than the list of countries from which CMs contained in the Covered Products were actually sourced.
After conducting its 2023 Program, and in light of the 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.
Steps to be taken in Calendar 2024
As Avnet endeavors not to purchase products that contain CMs that directly or indirectly finance or benefit armed groups in the Covered Countries, and to mitigate the risk of purchasing such products, it has continued with its Conflict Minerals Program discussed above during calendar year 2024 and specifically plans to pursue the following steps and improvements:
| · | Continue to engage with Suppliers that provided incomplete responses or no responses for 2023 to help encourage them to provide requested information for 2024. |
| · | Continue to encourage suppliers to improve their efforts and policies, particular with suppliers whose conflict minerals compliance programs and policies are deemed weak. |
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| · | For new in-scope suppliers: (i) communicate Avnet’s sourcing expectations, including through the dissemination of the Responsible Minerals Sourcing Policy and Global Supplier Quality Handbook and inclusion of CM sourcing requirements in supplier agreements; and (ii) provide access to training and educational resources on the requirements of the Conflict Minerals Rule and to guide them on best practices, completion of a CMRT and the use of the ASM platform. |
| · | Proactively analyze whether any CMs are present in future products that it develops or in existing products to the extent the materials included in such existing products are revised. |
| · | Proactively seek to include CM related provisions in new or amended supplier agreements with respect to the Covered Products. |
| · | Continue to monitor its Ethics Alertline for issues related to the Company’s conflict minerals program. |
Cautionary Statement about Forward-Looking Statements
Certain statements in this Report may be “forward-looking statements” within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange 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.
| 9 |
APPENDIX A
List of Smelters and Refiners
Avnet utilized data its Suppliers provided on their CMRTs for the 2023 Program along with RBA’s RMI due diligence of smelters and refiners to prepare the below list. The list: (1) may not include all smelters and refiners that processed CMs in the Covered Products, and (2) may include smelters and refiners that processed CMs which were not contained in the products provided by the Suppliers for the Covered Products.
For RMI Audit Status:
| · | “Conformant” means that the smelter or refiner has completed the independent annual audit process and been found to be in conformance with the relevant RMAP standard, whereby verified to have conflict-free sources. |
| · | “Active” means that the smelter or refiner is in the process of being independently audited or has committed to begin the audit process but has not yet been determined to be in conformance with the relevant RMAP standard. |
| · | “Non-Conformant” means that the smelter or refiner has been independently assessed but found not to be in conformance with the relevant RMAP standard. |
| · | “Communication Suspended – Not Interested” means the smelter or refiner has strongly communicated a lack of interest in participating in the audit program. |
| · | “Due Diligence Vetting Process” means the smelter or refiner does not meet RMI’s requirements for participation in the audit program according to the Due Diligence Vetting Process. |
| · | “In Communication” means the smelter or refiner is not yet active but is in communications with RMAP and/or a member company. |
| · | “Outreach Required” means RMI member companies need to contact entity to encourage their participation in audit program. |
| · | “RMI Due Diligence Review – Unable to Proceed” means the smelter or refiner has not met the thresholds for the Due Diligence Vetting Process after a period of 6 months. Status may change if additional information is submitted. |
| Mineral | Smelter / Refiner CID |
Smelter / Refiner Name | Smelter / Refiner Location |
RMI Audit Status |
| Gold | CID000015 | Advanced Chemical Company | United States Of America | Active |
| Gold | CID000019 | Aida Chemical Industries Co., Ltd. | Japan | Conformant |
| Gold | CID000035 | Agosi AG | Germany | Conformant |
| Gold | CID000041 | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan | Conformant |
| Gold | CID000058 | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil | Conformant |
| Gold | CID000077 | Argor-Heraeus S.A. | Switzerland | Conformant |
| Gold | CID000082 | Asahi Pretec Corp. | Japan | Conformant |
| Gold | CID000090 | Asaka Riken Co., Ltd. | Japan | Conformant |
| Gold | CID000103 | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | Turkey | Outreach Required |
| Gold | CID000113 | Aurubis AG | Germany | Conformant |
| Gold | CID000128 | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines | Conformant |
| Gold | CID000157 | Boliden AB | Sweden | Conformant |
| Gold | CID000176 | C. Hafner GmbH + Co. KG | Germany | Conformant |
| Gold | CID000180 | Caridad | Mexico | Outreach Required |
| Gold | CID000185 | CCR Refinery - Glencore Canada Corporation | Canada | Conformant |
| Gold | CID000189 | Cendres + Metaux S.A. | Switzerland | Non Conformant |
| 10 |
| Gold | CID000197 | Yunnan Copper 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 | Outreach Required |
| 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 | JSC Novosibirsk Refinery | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| 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 Germany 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 | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID000937 | JX Nippon Mining & Metals Co., Ltd. | Japan | Conformant |
| Gold | CID000956 | Kazakhmys Smelting LLC | Kazakhstan | Outreach Required |
| Gold | CID000957 | Kazzinc | Kazakhstan | Conformant |
| Gold | CID000969 | Kennecott Utah Copper LLC | United States Of America | Conformant |
| Gold | CID000981 | Kojima Chemicals Co., Ltd. | Japan | Conformant |
| Gold | CID001029 | Kyrgyzaltyn JSC | Kyrgyzstan | Non Conformant |
| 11 |
| Gold | CID001032 | L'azurde Company For Jewelry | Saudi Arabia | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID001056 | Lingbao Gold Co., Ltd. | China | Outreach Required |
| 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 | RMI Due Diligence Review - Unable to Proceed |
| 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 | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID001352 | MKS PAMP SA | Switzerland | Conformant |
| Gold | CID001362 | Penglai Penggang Gold Industry Co., Ltd. | China | Outreach Required |
| Gold | CID001386 | Prioksky Plant of Non-Ferrous Metals | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| 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 | Non 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 |
| 12 |
| 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 | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID001761 | Solar Applied Materials Technology Corp. | Taiwan, Province Of China | Conformant |
| Gold | CID001798 | Sumitomo Metal Mining Co., Ltd. | Japan | Conformant |
| Gold | CID001810 | Super Dragon Technology Co., Ltd. | Taiwan, Province Of 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 | Shandong Gold Smelting 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 | Outreach Required |
| Gold | CID002290 | SAFINA A.S. | Czechia | Conformant |
| Gold | CID002312 | Guangdong Jinding Gold Limited | China | Outreach Required |
| Gold | CID002314 | Umicore Precious Metals Thailand | Thailand | Non 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 | Non 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 | Non Conformant |
| Gold | CID002561 | Emirates Gold DMCC | United Arab Emirates | Non Conformant |
| Gold | CID002562 | International Precious Metal Refiners | United Arab Emirates | Outreach Required |
| 13 |
| Gold | CID002563 | Kaloti Precious Metals | United Arab Emirates | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID002567 | Sudan Gold Refinery | Sudan | Outreach Required |
| Gold | CID002580 | T.C.A S.p.A | Italy | Conformant |
| Gold | CID002582 | REMONDIS PMR B.V. | Netherlands | Conformant |
| Gold | CID002584 | Fujairah Gold FZC | United Arab Emirates | Outreach Required |
| Gold | CID002587 | Industrial 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 | Non Conformant |
| Gold | CID002615 | TOO Tau-Ken-Altyn | Kazakhstan | Conformant |
| Gold | CID002708 | Abington Reldan Metals, LLC | United States Of America | Conformant |
| Gold | CID002750 | Shenzhen CuiLu Gold Co., Ltd. | China | Outreach Required |
| Gold | CID002760 | Albino Mountinho Lda. | Portugal | Outreach Required |
| Gold | CID002761 | SAAMP | France | Non Conformant |
| Gold | CID002762 | L'Orfebre S.A. | Andorra | Conformant |
| Gold | CID002763 | 8853 S.p.A. | Italy | Non Conformant |
| Gold | CID002765 | Italpreziosi | Italy | Conformant |
| Gold | CID002778 | WIELAND Edelmetalle GmbH | Germany | Conformant |
| Gold | CID002779 | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria | Conformant |
| Gold | CID002850 | AU Traders and Refiners | South Africa | Non Conformant |
| Gold | CID002852 | GGC Gujrat Gold Centre Pvt. Ltd. | India | Non Conformant |
| Gold | CID002853 | Sai Refinery | India | Outreach Required |
| Gold | CID002857 | Modeltech Sdn Bhd | Malaysia | Non Conformant |
| Gold | CID002863 | Bangalore Refinery | India | Active |
| Gold | CID002865 | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| 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 | CID002920 | ABC Refinery Pty Ltd. | Australia | Outreach Required |
| Gold | CID002973 | Safimet S.p.A | Italy | Non Conformant |
| Gold | CID003153 | State Research Institute Center for Physical Sciences and Technology | Lithuania | Outreach Required |
| Gold | CID003185 | African Gold Refinery | Uganda | RMI Due Diligence Review - Unable to Proceed |
| Gold | CID003186 | Gold Coast Refinery | Ghana | Outreach Required |
| 14 |
| Gold | CID003189 | NH Recytech Company | Korea, Republic Of | Conformant |
| Gold | CID003324 | QG Refining, LLC | United States Of America | Outreach Required |
| Gold | CID003348 | Dijllah Gold Refinery FZC | United Arab Emirates | Outreach Required |
| Gold | CID003382 | CGR Metalloys Pvt Ltd. | India | Outreach Required |
| Gold | CID003383 | Sovereign Metals | India | Outreach Required |
| Gold | CID003424 | Eco-System Recycling Co., Ltd. North Plant | Japan | Conformant |
| Gold | CID003425 | Eco-System Recycling Co., Ltd. West Plant | Japan | Conformant |
| Gold | CID003461 | Augmont Enterprises Private Limited | India | Non Conformant |
| Gold | CID003463 | Kundan Care Products Ltd. | India | Outreach Required |
| Gold | CID003487 | Emerald Jewel Industry India Limited (Unit 1) | India | Outreach Required |
| Gold | CID003488 | Emerald Jewel Industry India Limited (Unit 2) | India | Outreach Required |
| Gold | CID003489 | Emerald Jewel Industry India Limited (Unit 3) | India | Outreach Required |
| Gold | CID003490 | Emerald Jewel Industry India Limited (Unit 4) | India | Outreach Required |
| Gold | CID003497 | K.A. Rasmussen | Norway | Outreach Required |
| Gold | CID003500 | Alexy Metals | United States Of America | Non Conformant |
| Gold | CID003548 | MD Overseas | India | Outreach Required |
| Gold | CID003557 | Metallix Refining Inc. | United States Of America | Outreach Required |
| Gold | CID003575 | Metal Concentrators SA (Pty) Ltd. | South Africa | Conformant |
| Gold | CID003615 | WEEEREFINING | France | Conformant |
| Gold | CID003641 | Gold by Gold Colombia | Colombia | Conformant |
| Gold | CID003663 | Dongwu Gold Group | China | Outreach Required |
| Gold | CID003666 | Sam Precious Metals | United Arab Emirates | Outreach Required |
| Gold | CID004010 | Coimpa Industrial LTDA | Brazil | Conformant |
| Gold | CID004506 | GG Refinery Ltd. | Tanzania, United Republic Of | Active |
| Gold | CID004697 | Attero Recycling Pvt Ltd | Outreach Required | |
| Tantalum | CID000460 | F&X Electro-Materials Ltd. | China | Conformant |
| Tantalum | CID000616 | XIMEI RESOURCES (GUANGDONG) LIMITED | China | Conformant |
| Tantalum | CID000914 | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China | Conformant |
| Tantalum | CID000917 | Jiujiang Tanbre Co., Ltd. | China | Conformant |
| Tantalum | CID001076 | AMG Brasil | Brazil | Conformant |
| Tantalum | CID001163 | Metallurgical Products India Pvt., Ltd. | India | Conformant |
| Tantalum | CID001175 | Mineracao Taboca S.A. | Brazil | Conformant |
| Tantalum | CID001192 | Mitsui Mining and Smelting Co., Ltd. | Japan | Conformant |
| Tantalum | CID001200 | NPM Silmet AS | Estonia | Conformant |
| Tantalum | CID001277 | Ningxia Orient Tantalum Industry Co., Ltd. | China | Conformant |
| Tantalum | CID001508 | QuantumClean | United States Of America | Conformant |
| Tantalum | CID001522 | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China | Conformant |
| 15 |
| Tantalum | CID001769 | Solikamsk Magnesium Works OAO | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| 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 |
| Tantalum | CID002539 | KEMET de Mexico | Mexico | Conformant |
| Tantalum | CID002544 | TANIOBIS Co., Ltd. | Thailand | Conformant |
| Tantalum | CID002545 | TANIOBIS GmbH | Germany | Conformant |
| Tantalum | CID002548 | Materion Newton Inc. | United States Of America | Conformant |
| Tantalum | CID002549 | TANIOBIS Japan Co., Ltd. | Japan | Conformant |
| Tantalum | CID002550 | TANIOBIS Smelting 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 | RFH Yancheng Jinye New Material Technology Co., Ltd. | China | Conformant |
| Tantalum | CID003926 | 5D Production OU | Estonia | Outreach Required |
| Tantalum | CID000291 | Guangdong Rising Rare Metals-EO Materials Ltd. | China | Conformant |
| Tantalum | CID004054 | PowerX Ltd. | Rwanda | 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 | Conformant |
| Tin | CID000313 | PT Premium Tin Indonesia | Indonesia | Conformant |
| 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 | Non Conformant |
| 16 |
| 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 Tin Combine | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| 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 | CID001419 | PT Bangka Tin Industry | Indonesia | Active |
| Tin | CID001421 | PT Belitung Industri Sejahtera | Indonesia | Conformant |
| Tin | CID001428 | PT Bukit Timah | Indonesia | Conformant |
| Tin | CID001453 | PT Mitra Stania Prima | Indonesia | Conformant |
| Tin | CID001457 | PT Panca Mega Persada | Indonesia | Outreach Required |
| Tin | CID001458 | PT Prima Timah Utama | Indonesia | Conformant |
| Tin | CID001460 | PT Refined Bangka Tin | Indonesia | Conformant |
| Tin | CID001463 | PT Sariwiguna Binasentosa | Indonesia | Conformant |
| Tin | CID001468 | PT Stanindo Inti Perkasa | Indonesia | Conformant |
| Tin | CID001477 | PT Timah Tbk Kundur | Indonesia | Conformant |
| Tin | CID001482 | PT Timah Tbk Mentok | Indonesia | Conformant |
| Tin | CID001486 | PT Timah Nusantara | Indonesia | Conformant |
| Tin | CID001490 | PT Tinindo Inter Nusa | Indonesia | Conformant |
| Tin | CID001493 | PT Tommy Utama | Indonesia | Conformant |
| Tin | CID001539 | Rui Da Hung | Taiwan, Province Of China | Conformant |
| Tin | CID001898 | Thaisarco | Thailand | Conformant |
| Tin | CID001908 | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China | Non 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 | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China | Conformant |
| Tin | CID002455 | CV Venus Inti Perkasa | Indonesia | Conformant |
| Tin | CID002468 | Magnu's Minerais Metais e Ligas Ltda. | Brazil | Conformant |
| 17 |
| Tin | CID002478 | PT Tirus Putra Mandiri | Indonesia | Communication Suspended - Not Interested |
| Tin | CID002500 | Melt Metais e Ligas S.A. | Brazil | Non Conformant |
| Tin | CID002503 | PT ATD Makmur Mandiri Jaya | Indonesia | Conformant |
| Tin | CID002517 | O.M. Manufacturing Philippines, Inc. | Philippines | Conformant |
| Tin | CID002570 | CV Ayi Jaya | Indonesia | 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 | CID002593 | PT Rajehan Ariq | Indonesia | Conformant |
| 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 | Conformant |
| Tin | CID002773 | Aurubis Beerse | Belgium | Conformant |
| Tin | CID002774 | Aurubis Berango | Spain | Conformant |
| Tin | CID002776 | PT Bangka Prima Tin | Indonesia | Conformant |
| Tin | CID002816 | PT Sukses Inti Makmur | Indonesia | Conformant |
| Tin | CID002835 | PT Menara Cipta Mulia | Indonesia | Conformant |
| Tin | CID002858 | Modeltech Sdn Bhd | Malaysia | Non Conformant |
| Tin | CID003116 | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China | Conformant |
| 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 | CID003381 | PT Rajawali Rimba Perkasa | Indonesia | Conformant |
| Tin | CID003387 | Luna Smelter, Ltd. | Rwanda | Conformant |
| Tin | CID003397 | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China | Conformant |
| Tin | CID003409 | Precious Minerals and Smelting Limited | India | Active |
| Tin | CID003410 | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China | Outreach Required |
| Tin | CID003449 | PT Mitra Sukses Globalindo | Indonesia | Conformant |
| Tin | CID003486 | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil | Conformant |
| Tin | CID003524 | CRM Synergies | Spain | Conformant |
| Tin | CID003582 | Fabrica Auricchio Industria e Comercio Ltda. | Brazil | Conformant |
| Tin | CID003831 | DS Myanmar | Myanmar | Conformant |
| Tin | CID003868 | PT Putera Sarana Shakti (PT PSS) | Indonesia | Conformant |
| 18 |
| Tin | CID002844 | HuiChang Hill Tin Industry Co., Ltd. | China | Conformant |
| Tin | CID003379 | Ma'anshan Weitai Tin Co., Ltd. | China | Non Conformant |
| Tin | CID004065 | Mining Minerals Resources SARL | Congo, Democratic Republic Of The | Conformant |
| Tin | CID004434 | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia | In Communication |
| 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 LLC | United States Of America | Conformant |
| Tungsten | CID000766 | Hunan Chenzhou Mining Co., Ltd. | China | Conformant |
| Tungsten | CID000769 | Hunan Jintai New Material Co., Ltd. | China | Non Conformant |
| Tungsten | CID000825 | Japan New Metals Co., Ltd. | Japan | 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 |
| 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 | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China | Conformant |
| Tungsten | CID002541 | H.C. Starck Tungsten GmbH | Germany | Conformant |
| Tungsten | CID002542 | TANIOBIS Smelting GmbH & Co. KG | Germany | Conformant |
| Tungsten | CID002543 | Masan High-Tech Materials | 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 Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID002649 | Hydrometallurg, JSC | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | CID002724 | Unecha Refractory metals plant | Russian Federation | Non Conformant |
| 19 |
| Tungsten | CID002827 | Philippine Chuangxin Industrial Co., Inc. | Philippines | Conformant |
| Tungsten | CID002833 | ACL Metais Eireli | Brazil | Non Conformant |
| Tungsten | CID002845 | Moliren Ltd. | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | CID003407 | Lianyou Metals Co., Ltd. | Taiwan, Province Of China | Conformant |
| Tungsten | CID003408 | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | CID003416 | NPP Tyazhmetprom LLC | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | CID003417 | Hubei Green Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID003427 | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil | Non Conformant |
| Tungsten | CID003468 | Cronimet Brasil Ltda | Brazil | Conformant |
| Tungsten | CID003553 | Artek LLC | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | CID003609 | Fujian Xinlu Tungsten Co., Ltd. | China | Conformant |
| Tungsten | CID003612 | OOO “Technolom” 2 | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | CID003614 | OOO “Technolom” 1 | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | CID003643 | LLC Vostok | Russian Federation | RMI Due Diligence Review - Unable to Proceed |
| Tungsten | CID003662 | YUDU ANSHENG TUNGSTEN CO., LTD. | China | Outreach Required |
| Tungsten | CID003978 | HANNAE FOR T Co., Ltd. | Korea, Republic Of | Outreach Required |
| Tungsten | CID003993 | Tungsten Vietnam Joint Stock Company | Viet Nam | Conformant |
| Tungsten | CID004060 | DONGKUK INDUSTRIES CO., LTD. | Korea, Republic Of | Outreach Required |
| Tungsten | CID004034 | Nam Viet Cromit Joint Stock Company | Viet Nam | Outreach Required |
| Tungsten | CID004397 | Lianyou Resources Co., Ltd. | Taiwan, Province Of China | Conformant |
| Tungsten | CID004430 | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. | China | Conformant |
| Tungsten | CID004619 | Kenee Mining Corporation Vietnam | Viet Nam | Active |
| 20 |
APPENDIX B
Countries of Origin
Avnet utilized data its suppliers provided on their CMRTs for the 2023 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 countries that ultimately sourced the CMs in the Covered Products, and (2) may include countries that did not ultimately source CMs contained in the Covered Products.
| Country of Origin (Material) | |||
| Albania | Ecuador | Kyrgyzstan | Saudi Arabia |
| Andorra | Egypt | Liberia | Senegal |
| Angola | El Salvador | Liechtenstein | Serbia |
| Argentina | Eritrea | Lithuania | Sierra Leone |
| Armenia | Estonia | Luxembourg | Singapore |
| Australia | Ethiopia | Madagascar | Slovakia |
| Austria | Fiji | Malaysia | South Africa |
| Azerbaijan | Finland | Mali | South Sudan |
| Belarus | France | Mauritania | Spain |
| Belgium | Georgia | Mexico | Sudan |
| Benin | Germany | Mongolia | Suriname |
| Bermuda | Ghana | Morocco | Sweden |
| Bolivia (Plurinational State of) | Guam | Mozambique | Switzerland |
| Botswana | Guatemala | Myanmar | Taiwan |
| Brazil | Guinea | Namibia | Tajikistan |
| Bulgaria | Guyana | Netherlands | Tanzania |
| Burkina Faso | Honduras | New Zealand | Thailand |
| Burundi | Hong Kong | Nicaragua | Togo |
| Cambodia | Hungary | Niger | Turkey |
| Canada | India | Nigeria | Uganda |
| Central African Republic | Indonesia | Norway | United Arab Emirates |
| Chile | Ireland | Oman | United Kingdom |
| China | Israel | Panama | United States of America |
| Colombia | Italy | Papua New Guinea | Uruguay |
| Congo | Ivory Coast | Peru | Uzbekistan |
| Cyprus | Japan | Philippines | VietNam |
| Democratic Republic of Congo | Jersey | Poland | Zambia |
| Djibouti | Kazakhstan | Portugal | |
| Dominica | Kenya | Russian Federation | |
| Dominican Republic | Korea | Rwanda | |
| 21 |