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 30, 2023


Exhibit 1.01
 

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Intuit Inc.
Conflict Minerals Report
For The Year Ended December 31, 2022

Conflict Minerals Rule

This Conflict Minerals Report ( “CMR”) of Intuit Inc. (“Intuit,” “we,” or “our”) for the year ended December 31, 2022 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 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 (“Conflict Minerals”). Rule 13p-1 focuses on Conflict Minerals originating from the Democratic Republic of Congo 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 and small businesses prosper by delivering financial management, compliance, and marketing products and services. We also provide specialized tax products to
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accounting professionals, who are key partners that help us serve small business customers. Our global technology platform, which includes TurboTax, Credit Karma, QuickBooks and Mailchimp, is designed to help consumers and small businesses manage their finances, save money, pay off debt and do their taxes. For those customers who run small businesses, we are focused on helping them find and keep customers, get paid faster, pay their employees, manage and get access to capital, and ensure that their books are done right. ProSeries and Lacerte are our leading tax preparation offerings for professional accountants. We refer to these brands herein as Intuit’s “Core Products” and they account for a 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 (“Intuit Payment Devices”).


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 2022 reporting period, the Intuit Payment Devices are the only products that Intuit contracted to manufacture that 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 (“Tier One Supplier”). Intuit does not directly purchase raw minerals, including Conflict Minerals, 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 calendar year 2022. 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
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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 an 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. 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 (collectively, 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.

Step 1: Establish Strong Company Management Systems

Intuit has established strong company management systems relating to conflict minerals. We have 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 in 2013. 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.
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Management has also developed a Conflict Minerals Policy that is posted at https://www.intuit.com/company/supplier-programs/policies/conflict-mineral-policy/ 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 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 & 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 Conflict Minerals contained in the Intuit Payment Devices, 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 (“Template”), which is designed to identify the smelters that process the Conflict Minerals in a company’s supply chain.

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”).

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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 Conflict Minerals. However, Intuit supports the development of, and smelters’ participation in, independent third-party audits of smelters’ sourcing practices, such as the RMAP.

Step 5: Report on Supply Chain Diligence

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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 https://www.intuit.com/company/supplier-programs/policies/conflict-mineral-policy/.

Results of Due Diligence

For the 2022 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, 135 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 smelters of Conflict Minerals that were RMAP-conformant during the 2022 reporting period.

Conflict Minerals Total Smelters in Supply Chain Total RMAP - Compliant Smelters % of RMAP- Compliant Smelters
Gold 62 62 100
Tantalum 28 28 100
Tin 25 25 100
Tungsten 20 20 100
Grand total 135 135 100

The percentage of Intuit’s RMAP-conformant smelters reflects our commitment to the Conflict Minerals Rules. For the each of the 2022, 2021, and 2020 reporting periods, 100% of the smelters identified in our supply chain were RMAP-conformant.

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Intuit cannot be certain that the list of 135 smelters is comprehensive and that there are no other smelters that 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.

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. 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 hereto, in fact contributed Conflict Minerals to Intuit Payment Devices. Annex B hereto 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.

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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.

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 that 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
2022 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. Corp. JAPAN
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA
Tungsten Global Tungsen & 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 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 High-Tech Materials VIET NAM
Tungsten TANIOBIS Smelting GmbH & Co. KG GERMANY
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 (Tin Smelting Branch of) CHINA
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 Gejiu Zili Mining And Metallurgy 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
Tin Mineracao Taboca S.A. BRAZIL
Tin PT ATD Makmur Mandiri Jaya INDONESIA
Tin PT Mitra Stania Prima INDONESIA
Tin PT Refined Bangka Tin INDONESIA
Tin PT Timah Tbk Kundur INDONESIA

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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
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 XIMEI RESOURCES (GUANGDONG) Limited CHINA
Tantalum TANIOBIS Co., Ltd THAILAND
Tantalum TANIOBIS GmbH GERMANY
Tantalum TANIOBIS Smelting GmbH & Co. KG GERMANY
Tantalum H.C. Starck Hermsdorf GmbH GERMANY
Tantalum H.C. Starck Inc. UNITED STATES OF AMERICA
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 de Mexico MEXICO
Tantalum AMG Brasil BRAZIL
Tantalum Mineracao Taboca S.A. BRAZIL
Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN
Tantalum Metallurgical Products India Pvt., Ltd. INDIA
Tantalum NPM Silmet AS ESTONIA
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA
Tantalum QuantumClean UNITED STATES OF AMERICA
Tantalum 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 Agosi AG 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
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Gold Chimet S.p.A. ITALY
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF
Gold DODUCO Contacts and Refining GmbH GERMANY
Gold Dowa JAPAN
Gold Eco-System Recycling Co., Ltd. East Plant JAPAN
Gold Heraeus Metals Hong Kong Ltd. CHINA
Gold Heraeus Germany 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
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 Shandong Gold Smelting 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
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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
India
Indonesia
Italy
Japan
Kazakhstan
Korea
Malaysia
Mexico
Philippines
Poland
Russia
Singapore
Spain
Switzerland
Taiwan
Thailand
Turkey
United States of America
Vietnam