EXHIBIT 1.01
Published on May 26, 2017
Exhibit 1.01
Intuit Inc.
Conflict Minerals Report
For The Year Ended December 31, 2016
Conflict Minerals Rule
This Conflict Minerals Report (the “CMR”) of Intuit Inc. ("Intuit") for the year ended December 31, 2016 is presented to comply with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended (the “1934 Act”). Rule 13p-1 imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) registrants that manufacture or contract to manufacture products containing certain minerals which are necessary to the functionality or production of those products. These minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). Rule 13p-1 focuses on 3TG originating from the Democratic Republic of Congo (“DRC”) and nine adjoining countries (together, the “Covered Countries”). If, based on a Reasonable Country of Origin Inquiry (“RCOI”), a registrant has reason to believe that any of the necessary Conflict Minerals contained in its products may have originated in the Covered Countries and may not be from recycled or scrap sources, then the registrant must exercise due diligence on such Conflict Minerals’ source and chain of custody.
Intuit Products
Intuit creates business and financial management software solutions that simplify the business of life for small businesses, consumers and accounting professionals. Our flagship products - QuickBooks, TurboTax and Mint - define our commitment to power prosperity around the world by revolutionizing the way people manage their personal finances, run small businesses and pay employees. Intuit has reviewed the products it manufactures or contracts to manufacture and has confirmed that none of its software products (including software products that are distributed on CDs as well as software products distributed through downloading or as a cloud-based service) contain Conflict Minerals. These core software offerings account for in excess of 95% of Intuit’s annual revenue.
In addition to these core software offerings, Intuit also contracts to manufacture a certain payment dongle that attaches to smart phones, tablets and Bluetooth card readers and allows merchants to process credit card payments (the “Intuit Payment Devices”). For the 2016 reporting period, the only product that Intuit manufactured or contracted to manufacture containing Conflict Minerals that are necessary to the functionality or production of such products are the Intuit Payment Devices. This CMR relates to the process undertaken for the Intuit Payment Devices.
Overview of Intuit’s Commitment to Responsible Sourcing
Intuit is committed to responsible sourcing and has been dedicated to ensuring that any Conflict Minerals contained in its products do not finance armed groups. Towards this end, Intuit has made notable progress in ensuring that Conflict Minerals are sourced from conflict-free smelters. As of December 31, 2016, all of the identified smelters in Intuit’s supply chain were audited as compliant by the Conflict-Free Sourcing Initiative's Conflict Free Smelter Program (“CFSP”), as discussed in the “Results of Due Diligence” section.
Reasonable Country of Origin Inquiry
Intuit conducted a RCOI to determine whether any of the necessary Conflict Minerals in the Intuit Payment Devices originated in the Covered Countries, or were Conflict Minerals from recycled or scrap sources by surveying our supply base for the Intuit Payment Devices. Based on its RCOI, Intuit was unable to determine that such Conflict Minerals did not originate in the Covered Countries or came from recycled or scrap sources, and, accordingly, we conducted due diligence on the source and chain of custody of such Conflict Minerals, as discussed below.
Design of Due Diligence Program
Intuit's due diligence program was designed to conform, in all material respects, to the five-step framework laid out in 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 and related Supplements on Tin, Tantalum and Tungsten and on Gold (the "OECD Guidance"). Below is a summary of the design of our due diligence program as it relates to the five-step framework under the OECD Guidance.
Establish Strong Company Management Systems
Intuit has established strong company management systems relating to conflict minerals. In January 2013, we formed a dedicated working group comprised of subject matter experts within the Supply Chain organization and Legal teams, and this working group has met regularly since its formation. The working group reports regularly on progress to a disclosure committee of senior executives, including the Chief Financial Officer, Chief Accounting Officer and General Counsel, and also updates the Audit and Risk Committee and Nominating and Governance Committee of the Board of Directors. Management has also developed a Conflict Minerals Policy that is posted at http://www.intuit.com/company/strategic-sourcing/supplier-policies/conflict-minerals/ to clearly communicate Intuit’s commitment to developing and maintaining a conflict free mineral supply chain to its suppliers and the public.
In addition, in order to improve on the quality of information provided by its supply chain, Intuit has already amended its agreements with its supplier to strengthen the contractual requirements to source from certified conflict-free sources wherever possible. Intuit requires the inclusion of similar provisions in its agreements with new suppliers.
Finally, we maintain a company-level grievance mechanism, as described in our Code of Conduct and Ethics, that enables employees to report concerns, including any concerns regarding Intuit's Conflict Minerals supply chain. Intuit also maintains an integrity hotline that third parties can use to report on financial and ethical issues, including issues concerning our Conflict Minerals supply chain. The number for this hotline is 1-877-379-3939.
Identify and Assess Risk in the Supply Chain
Intuit contracts to manufacture the Intuit Payment Devices with a sole direct supplier (the “Tier One Supplier”) that is at least four levels removed from the actual mining of the 3TGs. Intuit relies on the Tier One Supplier to provide information regarding the 3TG contained in those products, and the Tier One Supplier is similarly reliant upon information provided by its suppliers. Intuit has continued to make progress with its Tier One Supplier to establish controls over and transparency for its 3TG supply chain. In this process, Intuit used the due diligence tools developed by the Conflict-Free Sourcing Initiative (“CFSI”), including the CFSI’s Conflict Minerals Reporting Template (the “Template”), which is designed
to identify the smelters that process the Conflict Minerals in a company’s supply chain.
Intuit required its Tier One Supplier to disclose the original equipment manufacturers ("OEMs") that manufacture all of the components in the Intuit Payment Devices, and Intuit required each of the 47 identified OEMs to complete the Template. Intuit’s Tier One Supplier received a completed Template from all 47 OEMs. Once Intuit received the completed Templates, Intuit reviewed the Templates for completeness, accuracy and consistency. Where the Templates identified smelter facilities as sources of an OEM's 3TG, Intuit compared the identified smelters against the CFSI’s standard smelter list and the list of compliant smelters published by CFSP.
We are a member of the Electronic Industry Citizenship Coalition (“EICC”) and the CFSI working groups. As a member of CFSI, a leading industry program that helps its members to manage risk by improving supply chain transparency with respect to Conflict Minerals, Intuit has access to CFSI RCOI data that aids us in determining the mine or location of origin of the Conflict Minerals in our supply chain.
Intuit cannot be certain that the list of smelters identified in the Template responses as contributors of 3TG is comprehensive and that there are no other smelters that contribute to the 3TG in Intuit’s supply chain. However, based on the responses received from the identified smelters, the OEM component manufacturers have represented that they obtain their components from certified conflict free smelters who source the components from a mix of Covered Countries and non-Covered Countries, as discussed below under “Results of Due Diligence.” Where the Conflict Minerals are sourced from the Covered Countries, we have confirmed that such facilities identified by the OEM component manufacturers are certified by the CFSP as being conflict-free and not contributing to any armed groups in the Covered Countries. As a result, the primary risk in Intuit’s supply chain is the lack of verifiably complete information on the origin of the components utilized in the Intuit Payment Devices and due to such uncertainty, we are unable to determine that the Conflict Minerals utilized in the Intuit Payment Devices did not originate in the Covered Countries or directly or indirectly benefit armed groups.
Design and Implement a Strategy to Respond to Identified Risks
Intuit’s strategy to respond to the identified risks in its supply chain focuses on implementing requirements that its Tier One Supplier source the components in the Intuit Payment Devices from smelters certified under CFSI’s CFSP wherever possible. In this regard, where Template responses indicate that suppliers are not using certified conflict-free sources, we engaged with the Tier One Supplier and/or OEM to encourage them to establish an alternative source of Conflict Minerals. Intuit holds regular meetings with its Tier One Supplier to discuss and assess whether all of the suppliers in the supply chain are diligently working to get the Template completed in an accurate and timely manner. Based on the responses received by the Tier One Supplier, all of the identified smelters in Intuit’s supply chain are CFSP compliant.
Support Independent Third-Party Audit of Supply Chain Due Diligence
Intuit does not have direct relationships with smelters and does not perform direct audits of these entities' supply chains for 3TGs. However, Intuit supports the development of, and smelters' participation in, independent third party audits of smelters' sourcing practices, such as the CFSI's CFSP.
As a result of these independent third party audits of smelters’ sourcing practices, for 2016 all of the identified smelters are CFSP compliant in the Tier One Supplier’s supply chain.
Report on Supply Chain Diligence
Intuit is committed to full and transparent disclosure of its efforts to facilitate the sourcing of conflict-free minerals for its products. This CMR is available on Intuit's website at http://www.intuit.com/company/strategic-sourcing/supplier-policies/conflict-minerals/.
Due Diligence Measures Performed
For the 2016 reporting period, Intuit exercised vigilant due diligence as described above, on the source and chain of custody of the necessary Conflict Minerals contained in the Intuit Payment Devices that we had reason to believe may have originated from the Covered Countries and may not have come from recycled or scrap sources. Where Template responses identified smelter facilities as sources of an OEM’s 3TG, Intuit compared the identified smelters against the CFSI’s standard smelter list and the list of compliant smelters published by the CFSI’s CFSP to confirm that they have been certified as conflict-free by the CFSP.
Results of Due Diligence
Intuit's efforts to determine the mine or location of origin of the Conflict Minerals in the Intuit Payment Devices with the greatest possible specificity consisted of the due diligence measures described in this CMR, including our efforts to seek information from OEMs using the Template. 47 OEMs in Intuit’s supply chain completed the information requested in the Template. Based on responses we received from our Tier One Supplier, 168 smelters were identified in Intuit’s supply chain. All of the 168 identified smelters have been audited by and are compliant with CFSI’s CFSP. However, Intuit cannot be certain that the list of 168 smelters is comprehensive and that there are no other smelters which contribute to the component in Intuit’s Payment Device. Consequently, we are unable to determine that the Conflict Minerals utilized in the Intuit Payment Devices did not originate in the Covered Countries or directly or indirectly benefit armed groups.
The table below illustrates our results by providing, for each metal, the number and percentage of identified 3TG smelters that were CFSP compliant.
Row Labels |
Total Smelters in Supply Chain |
Total Eligible Smelters |
Total CFSP - Compliant Smelters |
% of CFSP- Compliant Smelters |
||||
Gold |
63 |
63 |
63 |
100 |
||||
Tantalum |
28 |
28 |
28 |
100 |
||||
Tin |
55 |
55 |
55 |
100 |
||||
Tungsten |
22 |
22 |
22 |
100 |
||||
Grand total |
168 |
168 |
168 |
100 |
||||
Although Intuit requested information from the OEMs at a product level, almost all supplier responses provided information at a company or division level, but not at a product level, and, therefore, the information provided was not necessarily limited to smelters confirmed to be in Intuit’s supply chain. As a result, Intuit is unable to validate whether the facilities identified by the OEMs, which are listed in Annex A below, in fact contributed Conflict Minerals to Intuit Payment Devices. Annex B below includes an aggregated list of the countries of origin from which the facilities listed in Annex A are believed to source Conflict Minerals, based on information provided by suppliers and CFSI, of which Intuit is a member.
Additional Mitigation Efforts
Intuit is also a member of the EICC and has developed procedures consistent with the EICC recommendations for responsible sourcing of Conflict Minerals, as set forth in the OECD Guidance. Intuit also attends the bi-weekly EICC Conflict Minerals Due Diligence Calls chaired by the EICC and has implemented the best practices that are relevant to its supply chain that have been developed by the CFSI. As an active member of the EICC, Intuit will continue to monitor and implement relevant best practices recommendations from the EICC as well as Conflict Minerals trends that impact Intuit’s business.
Further Intuit:
• |
Conducts benchmarking sessions with manufacturers and other technology companies in Silicon Valley; |
• |
Sets up Webinars with its suppliers to address concerns and questions; and |
• |
Continues to work with suppliers to see that they have robust due diligence practices. |
We also continue to work with our Tier One supplier and the EICC to ensure that our Tier One supplier continues to make all reasonable efforts to work with OEMs to source from smelters that are compliant with the CFSP.
Finally, while we are pleased with our progress in developing a conflict-free supply chain of Conflict Minerals in our existing products, we may continue to introduce new products, including devices which may contain certain Conflict Minerals necessary to their functionality or production. To that extent, we will continue to take all reasonable efforts to source such Conflict Minerals from smelters that are compliant with the CFSP.
ANNEX A
2016 Facility List
The following is a list of the facilities that the suppliers we surveyed reported as being in their supply chains.
Metal |
Standard Smelter Name |
Facility Location |
Tungsten |
A.L.M.T. TUNGSTEN Corp. |
Japan |
Gold |
Aida Chemical Industries Co., Ltd. |
Japan |
Gold |
Allgemeine Gold-und Silberscheideanstalt A.G. |
Germany |
Gold |
AngloGold Ashanti Córrego do Sítio Mineração |
Brazil |
Gold |
Argor-Heraeus S.A. |
Switzerland |
Gold |
Asahi Pretec Corp. |
Japan |
Gold |
Asaka Riken Co., Ltd. |
Japan |
Tungsten |
Kennametal Huntsville |
United States of America |
Gold |
Aurubis AG |
Germany |
Gold |
Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
Philippines |
Gold |
Boliden AB |
Sweden |
Gold |
C. Hafner GmbH + Co. KG |
Germany |
Gold |
CCR Refinery - Glencore Canada Corporation |
Canada |
Tantalum |
Changsha South Tantalum Niobium Co., Ltd. |
China |
Tungsten |
Guangdong Xianglu Tungsten Co., Ltd. |
China |
Gold |
Chimet S.p.A. |
Italy |
Tin |
Jiangxi Ketai Advanced Material Co., Ltd. |
China |
Tungsten |
Chongyi Zhangyuan Tungsten Co., Ltd. |
China |
Tantalum |
Conghua Tantalum and Niobium Smeltry |
China |
Tin |
Alpha |
United States of America |
Tin |
Cooperativa Metalurgica de Rondônia Ltda. |
Brazil |
Tin |
CV Gita Pesona |
Indonesia |
Tin |
PT Aries Kencana Sejahtera |
Indonesia |
Tin |
CV Serumpun Sebalai |
Indonesia |
Gold |
Dowa |
Japan |
Tin |
Dowa |
Japan |
Tantalum |
Duoluoshan |
China |
Gold |
Eco-System Recycling Co., Ltd. |
Japan |
Tin |
EM Vinto |
Bolivia (Plurinational State of) |
Tantalum |
Exotech Inc. |
United States of America |
Tantalum |
F&X Electro-Materials Ltd. |
China |
Tin |
Fenix Metals |
Poland |
Tungsten |
Fujian Jinxin Tungsten Co., Ltd. |
China |
Tin |
Gejiu Non-Ferrous Metal Processing Co., Ltd. |
China |
Tungsten |
Global Tungsten & Powders Corp. |
United States of America |
Tantalum |
Guangdong Zhiyuan New Material Co., Ltd. |
China |
Gold |
Heimerle + Meule GmbH |
Germany |
Gold |
Heraeus Ltd. Hong Kong |
China |
Gold |
Heraeus Precious Metals GmbH & Co. KG |
Germany |
Tantalum |
Hi-Temp Specialty Metals, Inc. |
United States of America |
Tungsten |
Hunan Chunchang Nonferrous Metals Co., Ltd. |
China |
Gold |
Ishifuku Metal Industry Co., Ltd. |
Japan |
Gold |
Istanbul Gold Refinery |
Turkey |
Tungsten |
Japan New Metals Co., Ltd. |
Japan |
Gold |
Jiangxi Copper Co., Ltd. |
China |
Tungsten |
Ganzhou Huaxing Tungsten Products Co., Ltd. |
China |
Tantalum |
JiuJiang JinXin Nonferrous Metals Co., Ltd. |
China |
Tantalum |
Jiujiang Tanbre Co., Ltd. |
China |
Gold |
Asahi Refining USA Inc. |
United States of America |
Gold |
Asahi Refining Canada Ltd. |
Canada |
Gold |
JX Nippon Mining & Metals Co., Ltd. |
Japan |
Gold |
Kennecott Utah Copper LLC |
United States of America |
Gold |
Kojima Chemicals Co., Ltd. |
Japan |
Tin |
China Tin Group Co., Ltd. |
China |
Tantalum |
LSM Brasil S.A. |
Brazil |
Gold |
LS-NIKKO Copper Inc. |
Korea (Republic of) |
Tin |
Malaysia Smelting Corporation (MSC) |
Malaysia |
Gold |
Materion |
United States of America |
Gold |
Matsuda Sangyo Co., Ltd. |
Japan |
Tin |
Metallic Resources, Inc. |
United States of America |
Gold |
Metalor Technologies (Hong Kong) Ltd. |
China |
Gold |
Metalor Technologies (Singapore) Pte., Ltd. |
Singapore |
Gold |
Metalor Technologies S.A. |
Switzerland |
Gold |
Metalor USA Refining Corporation |
United States of America |
Gold |
Metalúrgica Met-Mex Peñoles S.A. De C.V. |
Mexico |
Tin |
Mineração Taboca S.A. |
Brazil |
Tantalum |
Mineração Taboca S.A. |
Brazil |
Tin |
Minsur |
Peru |
Gold |
Mitsubishi Materials Corporation |
Japan |
Tin |
Mitsubishi Materials Corporation |
Japan |
Tantalum |
Mitsui Mining and Smelting Co., Ltd. |
Japan |
Gold |
Mitsui Mining and Smelting Co., Ltd. |
Japan |
Gold |
Nadir Metal Rafineri San. Ve Tic. A.ª. |
Turkey |
Gold |
Nihon Material Co., Ltd. |
Japan |
Tantalum |
Ningxia Orient Tantalum Industry Co., Ltd. |
China |
Tin |
O.M. Manufacturing (Thailand) Co., Ltd. |
Thailand |
Gold |
Elemetal Refining, LLC |
United States of America |
Gold |
Ohura Precious Metal Industry Co., Ltd. |
Japan |
Tin |
Operaciones Metalurgical S.A. |
Bolivia (Purinational State of) |
Gold |
PAMP S.A. |
Switzerland |
Gold |
PT Aneka Tambang (Persero) Tbk |
Indonesia |
Tin |
PT Artha Cipta Langgeng |
Indonesia |
Tin |
PT Babel Inti Perkasa |
Indonesia |
Tin |
PT Bangka Tin Industry |
Indonesia |
Tin |
PT Belitung Industri Sejahtera |
Indonesia |
Tin |
PT Bukit Timah |
Indonesia |
Tin |
PT DS Jaya Abadi |
Indonesia |
Tin |
PT Eunindo Usaha Mandiri |
Indonesia |
Tin |
PT Mitra Stania Prima |
Indonesia |
Tin |
PT Panca Mega Persada |
Indonesia |
Tin |
PT Prima Timah Utama |
Indonesia |
Tin |
PT Refined Bangka Tin |
Indonesia |
Tin |
PT Sariwiguna Binasentosa |
Indonesia |
Tin |
PT Stanindo Inti Perkasa |
Indonesia |
Tin |
PT Sumber Jaya Indah |
Indonesia |
Tin |
PT Timah (Persero) Tbk Kundur |
Indonesia |
Tin |
PT Timah (Persero) Tbk Mentok |
Indonesia |
Tin |
PT Tinindo Inter Nusa |
Indonesia |
Gold |
PX Précinox S.A. |
Switzerland |
Gold |
Rand Refinery (Pty) Ltd. |
South Africa |
Gold |
Royal Canadian Mint |
Canada |
Tin |
Rui Da Hung |
Taiwan, Province of China |
Gold |
SEMPSA Joyería Platería S.A. |
Spain |
Gold |
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
China |
Gold |
SOE Shyolkovsky Factory of Secondary Precious Metals |
Russian Federation |
Tin |
Soft Metais Ltda. |
Brazil |
Gold |
Solar Applied Materials Technology Corp. |
Taiwan, Province of China |
Tantalum |
Solikamsk Magnesium Works OAO |
Russian Federation |
Gold |
Sumitomo Metal Mining Co., Ltd. |
Japan |
Gold |
Tanaka Kikinzoku Kogyo K.K. |
Japan |
Tungsten |
Tejing (Vietnam) Tungsten Co., Ltd. |
Vietnam |
Tantalum |
Telex Metals |
United States of America |
Tin |
Thaisarco |
Thailand |
Gold |
The Refinery of Shandong Gold Mining Co., Ltd. |
China |
Gold |
Tokuriki Honten Co., Ltd. |
Japan |
Tantalum |
Ulba Metallurgical Plant JSC |
Kazakhstand |
Gold |
Umicore Brasil Ltda. |
Brazil |
Gold |
Umicore S.A. Business Unit Precious Metals Refining |
Belgium |
Gold |
United Precious Metal Refining, Inc. |
United States of America |
Gold |
Valcambi S.A. |
Switzerland |
Tin |
VQB Mineral and Trading Group JSC |
Vietnam |
Gold |
Western Australian Mint trading as The Perth Mint |
Australia |
Tin |
White Solder Metalurgia e Mineração Ltda. |
Brazil |
Tungsten |
Wolfram Bergbau und Hütten AG |
Austria |
Tungsten |
Xiamen Tungsten Co., Ltd. |
China |
Gold |
Yamamoto Precious Metal Co., Ltd. |
Japan |
Gold |
Yokohama Metal Co., Ltd. |
Japan |
Tin |
Yunnan Tin Company Limited |
China |
Gold |
Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
China |
Gold |
Zijin Mining Group Co., Ltd. Gold Refinery |
China |
Tantalum |
Yichun Jin Yang Rare Metal Co., Ltd. |
China |
Gold |
Umicore Precious Metals Thailand |
Thailand |
Tungsten |
Xiamen Tungsten (H.C.) Co., Ltd. |
China |
Tin |
CV Venus Inti Perkasa |
Indonesia |
Tin |
Magnu's Minerais Metais e Ligas Ltda. |
Brazil |
Tin |
PT Wahana Perkit Jaya |
Indonesia |
Tantalum |
Hengyang King Xing Lifeng New Materials Co., Ltd. |
China |
Tungsten |
Ganzhou Seadragon W & Mo Co., Ltd. |
China |
Tin |
Melt Metais e Ligas S.A. |
Brazil |
Tin |
PT ATD Makmur Mandiri Jaya |
Indonesia |
Tantalum |
D Block Metals, LLC |
United States of America |
Gold |
Republic Metals Corporation |
United States of America |
Tungsten |
Chenzhou Diamond Tungsten Products Co., Ltd. |
China |
Tin |
O.M. Manufacturing Philippines, Inc. |
Philippines |
Tin |
PT Inti Stania Prima |
Indonesia |
Tantalum |
Plansee SE Liezen |
Austria |
Tungsten |
H.C. Starck GmbH |
Germany |
Tungsten |
H.C. Starck Smelting GmbH & Co.KG |
Germany |
Tungsten |
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC |
Vietnam |
Tantalum |
H.C. Starck Co., Ltd. |
Thailand |
Tantalum |
H.C. Starck GmbH Goslar |
Germany |
Tantalum |
H.C. Starck Hermsdorf GmbH |
Germany |
Tantalum |
H.C. Starck Inc. |
United States of America |
Tantalum |
H.C. Starck Ltd. |
Japan |
Tantalum |
H.C. Starck Smelting GmbH & Co. KG |
Germany |
Tungsten |
Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
China |
Tantalum |
Plansee SE Reutte |
Austria |
Tantalum |
Global Advanced Metals Boyertown |
United States of America |
Tantalum |
Global Advanced Metals Aizu |
Japan |
Tin |
CV Ayi Jaya |
Indonesia |
Tungsten |
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji |
China |
Tungsten |
Niagara Refining LLC |
United States of America |
Tungsten |
Hydrometallurg, JSC |
Russian Federation |
Tin |
PT Cipta Persada Mulia |
Indonesia |
Tin |
Resind Indústria e Comércio Ltda. |
Brazil |
Tin |
Metallo-Chimique N.V. |
Belgium |
Tin |
Elmet S.L.U. |
Spain |
Tin |
PT Bangka Prima Tin |
Indonesia |
ANNEX B
Countries of origin of the Conflict Minerals that the facilities listed in Annex A process are believed to include the following countries, based on information provided by suppliers and CFSI:
L1 |
L2 |
Level 1 countries are not identified as conflict regions or plausible areas of smuggling or export from the DRC and its nine adjoining countries. |
Level 2 countries are known or plausible countries for smuggling, export out of region or transit of materials containing tantalum, tin, tungsten or gold. |
Australia |
South Africa* |
Austria |
|
Belgium | |
Bolivia | |
Brazil | |
Canada | |
China | |
Germany | |
Hong Kong | |
Indonesia | |
Italy | |
Japan | |
Kazakhstan | |
Korea | |
Malaysia | |
Mexico | |
Peru | |
Philippines | |
Poland | |
Russia | |
Singapore | |
Spain | |
Sweden | |
Switzerland | |
Taiwan | |
Thailand | |
Turkey | |
United States of America | |
Vietnam | |
* Rand Refineries is the only smelter that may be in Intuit's supply chain and that is located in South Africa and is a CFSP compliant smelter | |