Form: SD

Specialized Disclosure Report filed pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to the use of conflict minerals (Rule 13p-1)

May 27, 2020



Exhibit 1.01
 

Intuit Inc.
Conflict Minerals Report
For The Year Ended December 31, 2019

Conflict Minerals Rule

This Conflict Minerals Report (the “CMR”) of Intuit Inc. (“Intuit”) for the year ended December 31, 2019 is presented to comply with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934, as amended (the “Conflict Mineral Rules”). 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.


Company overview

Intuit helps consumers, small businesses and the self-employed prosper by delivering financial management and compliance products and services. Our flagship brands, QuickBooks and TurboTax, help customers run their small businesses, pay employees and bills, separate business and personal expenses, track their money, and file income taxes (“Core Products”). Intuit’s Core Products account for majority of our total annual revenue. These offerings include software products distributed through downloading, cloud-based services and CDs. In addition to these core software offerings, Intuit also contracts to manufacture a bluetooth card reader that connects to smart phones and tablets and allows merchants to process credit card payments (the “Intuit Payment Devices”).



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Conflict Minerals Rule Applicability

Intuit has reviewed the products it manufactures or contracts to manufacture and has confirmed that none of its Core Products described above contain Conflict Minerals. For the 2019 reporting period, the Intuit Payment Devices are the only products that Intuit contracted to manufacture which contain Conflict Minerals that are necessary to their functionality or production. This CMR relates to the due diligence process undertaken for the Intuit Payment Devices.

Intuit contracts to manufacture the Intuit Payment Devices with one direct supplier (the “Tier One Supplier”). Intuit does not directly purchase raw minerals, including 3TG, and is many steps removed from the mines, smelters and refiners that supply the conflict minerals contained in the Intuit Payment Devices.

Statements in this CMR are based on our due diligence activities performed in good faith for the calendar year 2019. Factors that could affect the accuracy of the statements in this CMR include but are not limited to, incomplete supplier or smelter data available through suppliers or smelters, on-going certification of smelters, continued guidance or amendments to the Conflict Minerals Rules and other factors.

 
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.


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, Third Edition and related Supplements on Tin, Tantalum and Tungsten and on Gold (the “OECD

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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.

Step 1: 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 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 suppliers 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.

Step 2: Identify and Assess Risk in the Supply Chain

Intuit relies on the Tier One Supplier to provide information regarding the 3TG contained in our products, and the Tier One Supplier is similarly reliant upon information provided by its suppliers. In this process, Intuit used the due diligence tools developed by the Responsible Minerals Initiative (“RMI”), including the RMI’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.


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Intuit reviewed the Templates provided by the Tier One Supplier for completeness, accuracy and consistency. Intuit compared the identified smelters against the RMI’s standard smelter list and the list of compliant smelters published by the Responsible Minerals Assurance Process (“RMAP”).

We are a member of the Responsible Business Alliance (“RBA”) and the RMI working groups. As a member of the RMI, 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 RMI RCOI data that aids us in determining the mine or location of origin of the Conflict Minerals in our supply chain.

Step 3: 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 RMAP wherever possible. In this regard, where Template responses indicate that suppliers are not using sources that have been certified as conformant to an independent third-party audit program such as RMAP, we engaged with the Tier One Supplier and/or Original Equipment Manufacturer (“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. We also update our Audit and Risk Committee at least annually on our conflict minerals reporting.

Step 4: Support Independent Third-Party Audit of Supply Chain Due Diligence

Intuit does not have direct relationships with smelters and is many steps removed from the mines, smelters and refiners. We do not perform direct audits of these entities’ supply chains for 3TGs. However, Intuit supports the development of, and smelter’ participation in, independent third party audits of smelters’ sourcing practices, such as the RMAP.

Step 5: Report on Supply Chain Diligence

Intuit is committed to full and transparent disclosure of its efforts to facilitate the responsible sourcing of minerals for its products. This CMR is available on Intuit’s website at http://www.intuit.com/company/strategic-sourcing/supplier-policies/conflict-minerals/.


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Results of Due Diligence

For the 2019 reporting period, we had reason to believe that the Conflict Minerals contained in the Intuit Payment Devices may have originated from the Covered Countries and may not have come from recycled or scrap sources. Intuit exercised vigilant due diligence as described above on the source and chain of custody of these necessary Conflict Minerals.

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 our suppliers using the Template. Based on responses we received from our Tier One Supplier, 152 smelters were identified in Intuit’s supply chain. All of the identified smelters have been audited by the RMAP.

The table below illustrates our results by providing, for each relevant metal, the number and percentage of identified 3TG smelters that were RMAP conformant during the 2019 reporting period.


Conflict Minerals
Total Smelters in Supply Chain
Total RMAP - Compliant Smelters
% of RMAP- Compliant Smelters
Gold
63

62

98

Tantalum
26

26

100

Tin
42

42

100

Tungsten
21

21

100

Grand total
152

151

99


The percentage of Intuit’s RMAP-conformant smelters reflects our commitment to the Conflict Minerals Rules. For the 2018 reporting period, we disclosed in our CMR that 99% of the identified smelters were RMAP conformant. One tin smelter did not appear on the RMAP-conformant list because it had shut down its operations permanently during 2018. The percentage of RMAP-conformant smelters remained 99% in the 2019 reporting period for the same reason. One gold smelter shut down during 2019 and therefore was not classified as conformant. This is reflected in the table above.

Intuit cannot be certain that the list of 152 smelters is comprehensive and that there are no other smelters which contribute to the components in the Intuit Payment Devices. 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.


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Although Intuit requested information from the suppliers 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 the RMI, of which Intuit is a member.

Additional Mitigation Efforts

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 responsibly sourced from smelters that are conformant with RMAP.

Intuit is also a member of the RBA and has developed procedures consistent with the RBA recommendations for responsible sourcing of Conflict Minerals, as set forth in the OECD Guidance. Intuit also attends the bi-weekly RBA Conflict Minerals Due Diligence Calls chaired by the RBA and has implemented the best practices that are relevant to its supply chain that have been developed by the RMI. As an active member of the RBA, Intuit will continue to monitor and implement relevant best practices recommendations from the RBA as well as Conflict Minerals trends that impact Intuit’s business.

Further, Intuit:

While on-boarding our Tier One Supplier, included a provision in the supplier contract to ensure that it is committed to responsible sourcing of Conflict Minerals;
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 RBA 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 RMAP.


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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 RMAP.




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ANNEX A
2019 Facility List

The following is a list of the facilities that the suppliers we surveyed reported as being in their supply chains.

Mineral
Smelter Name
Country
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
Tungsten
Japan New Metals Co., Ltd.
JAPAN
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
Tungsten
Masan Tungsten Chemical LLC (MTC)
VIET NAM
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
Tin
Alpha
UNITED STATES OF AMERICA
Tin
China Tin Group Co., Ltd.
CHINA
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Tin Company Limited
CHINA
Tin
CV Gita Pesona
INDONESIA
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
PT Premium Tin Indonesia
INDONESIA
Tin
CV United Smelting
INDONESIA
Tin
Dowa
JAPAN
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
Tin
Fenix Metals
POLAND
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
Tin
Magnu’s Minerais Metais e Ligas Ltda.
BRAZIL
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
Tin
Melt Metais e Ligas S.A.
BRAZIL

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Tin
Mineracao Taboca S.A.
BRAZIL
Tin
Mitsubishi Materials Corporation
JAPAN
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
Tin
Operaciones Metalurgicas S.A.
BOLIVIA (PLURINATIONAL STATE OF)
Tin
CV Ayi Jaya
INDONESIA
Tin
PT Aries Kencana Sejahtera
INDONESIA
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
Tin
PT Bukit Timah
INDONESIA
Tin
PT DS Jaya Abadi
INDONESIA
Tin
PT Inti Stania Prima
INDONESIA
Tin
PT Karimun Mining
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 Sumber Jaya Indah
INDONESIA
Tin
PT Timah Tbk Kundur
INDONESIA
Tin
PT Timah Tbk Mentok
INDONESIA
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
Tin
Soft Metais Ltda.
BRAZIL
Tin
Thaisarco
THAILAND
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
Tin
Yunnan Tin Company Limited
CHINA
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
Tantalum
F&X Electro-Materials Ltd.
CHINA
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
Tantalum
Global Advanced Metals Aizu
JAPAN
Tantalum
Guangdong Zhiyuan New Material Co., Ltd.
CHINA
Tantalum
H.C. Starck Co., Ltd.
THAILAND
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
Tantalum
KEMET Blue Metals
MEXICO
Tantalum
LSM Brasil S.A.
BRAZIL
Tantalum
Mineracao Taboca S.A.
BRAZIL
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
Tantalum
Metallurgical Products India Pvt., Ltd.
INDIA

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Tantalum
NPM Silmet AS
ESTONIA
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
Tantalum
QuantumClean
UNITED STATES OF AMERICA
Tantalum
RFH Tantalum Smeltery Co., Ltd./Yanling Jincheng Tantalum & Niobium Co., Ltd.
CHINA
Tantalum
Solikamsk Magnesium Works OAO
RUSSIAN FEDERATION
Tantalum
Taki Chemical Co., Ltd.
JAPAN
Tantalum
Telex Metals
UNITED STATES OF AMERICA
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
Gold
Argor-Heraeus S.A.
SWITZERLAND
Gold
Asahi Pretec Corp.
JAPAN
Gold
Asahi Refining Canada Ltd.
CANADA
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
Gold
Asaka Riken Co., Ltd.
JAPAN
Gold
Aurubis AG
GERMANY
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Cendres + Metaux S.A.
SWITZERLAND
Gold
Chimet S.p.A.
ITALY
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
Gold
DODUCO Contacts and Refining GmbH
GERMANY
Gold
Dowa
JAPAN
Gold
Eco-System Recycling Co., Ltd.
JAPAN
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
Gold
Istanbul Gold Refinery
TURKEY
Gold
Japan Mint
JAPAN
Gold
Jiangxi Copper Co., Ltd.
CHINA
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
Gold
Kazzinc
KAZAKHSTAN
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
Gold
Kojima Chemicals Co., Ltd.
JAPAN
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
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
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
Gold
Mitsubishi Materials Corporation
JAPAN

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Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
Gold
Nihon Material Co., Ltd.
JAPAN
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
Gold
OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)
RUSSIAN FEDERATION
Gold
PAMP S.A.
SWITZERLAND
Gold
PX Precinox S.A.
SWITZERLAND
Gold
Royal Canadian Mint
CANADA
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
Gold
Umicore Precious Metals Thailand
THAILAND
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
Gold
Valcambi S.A.
SWITZERLAND
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
Gold
Yamakin Co., Ltd.
JAPAN
Gold
Yokohama Metal Co., Ltd.
JAPAN
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA



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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 RMI:

L1
L2
Level 1 countries are not identified as conflict regions or plausible countries for smuggling, export or transit of materials containing tantalum, tin, tungsten or gold from the Covered Countries.
Level 2 countries are known Covered Countries or plausible countries for smuggling, export or transit of materials containing tantalum, tin, tungsten or gold from the Covered Countries.
Australia

Austria
 
Belgium
Bolivia
Brazil
Canada
China
Estonia
Germany
Hong Kong
India
Indonesia
Italy
Japan
Kazakhstan
Korea
Malaysia
Mexico
Philippines
Poland
Russia
Singapore
Spain
Sweden
Switzerland
Taiwan
Thailand
Turkey
United States of America
Vietnam



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