UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
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INTEL CORPORATION
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(Exact name of the registrant as specified in its charter)
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Delaware
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000-06217
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94-1672743
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(State or other jurisdiction of incorporation)
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(Commission File Number)
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(IRS Employer Identification No.)
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2200 Mission College Boulevard, Santa Clara, California
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95054-1549
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(Address of principal executive offices)
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(Zip code)
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Suzan A. Miller
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(408) 765-8080
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(Name and telephone number, including area code, of the person to contact in connection with this report.)
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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:
√ Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014
Introduction
This Specialized Disclosure Report on Form SD ("Form SD") of Intel Corporation ("Intel" or "we") for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended ("Rule"). The Rule was adopted by the Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to "conflict minerals" as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank Act"). Conflict minerals are defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. The Rule imposes certain reporting obligations on SEC registrants whose products contain conflict minerals that are necessary to the functionality or production of their products (such minerals are referred to as "necessary conflict minerals"), excepting conflict minerals that, prior to January 31, 2013, were located "outside of the supply chain" (as defined in the Rule). For products which contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the conflict minerals originated in the Democratic Republic of the Congo ("DRC") or an adjoining country, collectively defined as the "Covered Countries". If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals contained in its products originated or may have originated in a Covered Country and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources, the registrant must conduct due diligence as a method to conclude if the necessary conflict minerals contained in those products did or did not directly or indirectly finance or benefit armed groups in the Covered Countries. Products which do not contain necessary conflict minerals that directly or indirectly finance or benefit armed groups in the Covered Countries are considered "DRC conflict free". We use the term "conflict free" in this Form SD in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the Covered Countries. Numerous terms in this Form SD are defined in the Rule and the reader is referred to that source and to SEC Release No. 34-67716 issued by the Securities and Exchange Commission on August 22, 2012 for such definitions.
Company Overview
We design and manufacture advanced integrated digital technology platforms. A platform consists of a microprocessor and chipset, and may be enhanced by additional hardware, software, and services. We sell these platforms primarily to original equipment manufacturers, original design manufacturers, and industrial and communications equipment manufacturers in the computing and communications industries. Our platforms are used to deliver a wide range of computing experiences in notebooks (including Ultrabook™ devices), 2 in 1 systems, desktops, servers, tablets, smartphones, and the Internet of Things (including wearables, transportation systems, and retail devices). We also develop and sell software and services primarily focused on security and technology integration.
Overview of Intel's Conflict Minerals Program
As a semiconductor manufacturer, we are knowledgeable of the design of our products including the materials needed to construct them. We design the manufacturing processes to build those products and in some cases, design the detailed materials to manufacture those products. As a result, we know that many of our hardware products contain tantalum, tin, tungsten and/or gold that is necessary to the functionality or production of those products. Conflict minerals are obtained from sources worldwide, and our desire is not to eliminate those originating in the Covered Countries but rather to obtain conflict minerals from sources that do not directly or indirectly finance or benefit armed groups in the Covered Countries. We believe that it is important for us and other companies to support responsible in-region mineral sourcing from the Covered Countries in order to not negatively affect the economies of such countries. Intel is a founding member of the Public Private Alliance for Responsible Minerals Trade (PPA). We participate in the "Solutions for Hope" project that provides suppliers with tantalum from conflict free sources in the DRC, and we are an associate member of the ITRI Tin Supply Chain Initiative (iTSCi) that establishes traceability in the upstream mineral chain in the DRC, Rwanda and Burundi.
We are an industry leader in the conflict minerals subject area, where we have worked extensively for over seven years to put in place processes and systems to develop conflict free supply chains for Intel and our industry. We recognize that broad collaborative efforts among governments, non-governmental organizations and industry are needed to solve this complex problem. Intel is a member of the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI)'s Conflict-Free Sourcing Initiative ("CFSI", unique member code INTC) and as such, are working with companies in the electronics and other industries that use necessary conflict minerals (e.g., jewelry, automotive, medical instrumentation, and others) to help create conflict free supply chains. In 2013 and 2014, we manufactured microprocessors that are DRC conflict free for tantalum, tin, tungsten and gold. In 2015, we are continuing our work to establish conflict free supply chains for these conflict minerals.
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Conflict Minerals Sourcing Policy
Intel's policy with respect to the sourcing of conflict minerals is as follows:
Conflict minerals originating from the DRC are sometimes mined and sold, "under the control of armed groups", to "finance conflict characterized by extreme levels of violence". Some of these minerals can make their way into the supply chains of the products used around the world, including those in the electronics industry. Intel's suppliers acquire and use conflict minerals from multiple sources worldwide. As part of Intel's commitment to corporate responsibility and respecting human rights in our own operations and in our global supply chain, it is Intel's goal to use tantalum, tin, tungsten and gold in our products that do not directly or indirectly finance or benefit armed groups in the Covered Countries while continuing to support responsible mineral sourcing in the region.
We expect our suppliers to have in place policies and due diligence measures that will enable us to reasonably assure that products and components supplied to us containing conflict minerals are DRC conflict free. We further expect our suppliers to comply with the EICC Code of Conduct and conduct their business in alignment with Intel's supply chain responsibility expectations.
In support of this policy, we will:
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Exercise due diligence with relevant suppliers consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and encourage our suppliers to do likewise with their suppliers.
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Provide, and expect our suppliers to cooperate in providing, due diligence information to confirm the tantalum, tin, tungsten and gold in our supply chain are conflict free.
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Collaborate with our suppliers and others on industry-wide solutions to enable products that are DRC conflict free.
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Commit to transparency in the implementation of this policy by making available reports on our progress to relevant stakeholders and the public.
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The full text of our Conflict Minerals Sourcing Policy is available at www.intel.com/conflictfree. The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Supply Chain Description
Most of our hardware products, primarily microprocessors, chipsets and their packages, are manufactured in our own network of fabrication facilities ("fabs"). Although many of our hardware products contain conflict minerals, we do not purchase ore or unrefined conflict minerals from mines, and we are many steps removed in the supply chain from the mining of the conflict minerals. We purchase materials used in our products from a large network of suppliers; some of those materials contribute necessary conflict minerals to our products. The origin of conflict minerals cannot be determined with any certainty once the ores are smelted, refined and converted to ingots, bullion or other conflict minerals containing derivatives. The smelters and refiners (sometimes referred to as "facilities") are consolidating points for ore and are in the best position in the total supply chain to know the origin of the ores. We rely on our suppliers to assist with our reasonable country of origin inquiry and due diligence efforts, including the identification of smelters and refiners, for the conflict minerals contained in the materials which they supply to us. We are more knowledgeable about the source and chain of custody of the necessary conflict minerals contained in products we fully manufacture in our fabs as compared to products which we manufacture but also include ready-made component parts we purchase from third parties or products that are manufactured for us by other companies.
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SECTION 1 - CONFLICT MINERALS DISCLOSURE
Item 1.01 Conflict Minerals Disclosure and Report
Conclusion Based on Reasonable Country of Origin Inquiry
Intel has concluded in good faith that during 2014,
a)
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Intel has manufactured and contracted with others to manufacture products as to which conflict minerals are necessary to the functionality or production of our products.
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b)
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Based on a reasonable country of origin inquiry ("RCOI"), Intel knows or has reason to believe that a portion of its necessary conflict minerals originated or may have originated in the Covered Countries and knows or has reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources.
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Description of Reasonable Country of Origin Inquiry Efforts
For 2014, we conducted a supply chain survey with our suppliers to obtain country of origin information for the necessary conflict minerals in our products using the Conflict Minerals Reporting Template (CMRT). That supply chain survey requests our suppliers to identify the smelters and refiners and countries of origin of the conflict minerals in products they supply to Intel. We compared the smelters and refiners identified in the surveys against the lists of facilities which have received a conflict free designation by the CFSP or other independent third party audit program such as the London Bullion Market Association's Responsible Gold Programme and the Responsible Jewellery Council's Chain-of-Custody Certification program. If a smelter or refiner in our supply chain was not listed as having received a "conflict free" designation, we proactively attempted to contact such facility to request country of origin information for the conflict minerals that it processed. We documented country of origin information for the smelters and refiners identified by the supply-chain survey as provided from multiple sources including the supply-chain survey, independent third party audit programs and directly from smelters and refiners that Intel contacted.
There is significant overlap between our RCOI efforts and our due diligence measures performed. Our due diligence measures performed are discussed further in the Conflict Minerals Report filed as Exhibit 1.01 hereto.
Below is a summary of the country of origin information collected as a result of our RCOI efforts.
Conflict Mineral
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Countries of origin and other sources may include the following
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Tantalum
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Australia, Belarus, Bolivia, Brazil, Burundi, Canada, China, DRC, Estonia, Ethiopia, Germany, India, Japan, Kazakhstan, Malaysia, Mozambique, Namibia, Niger, Nigeria, Russian Federation, Rwanda, Sierra Leone, Thailand, United States, Zimbabwe and recycled or scrap sources
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Tin
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Australia, Bolivia, Brazil, Canada, Chile, China, DRC, Indonesia, Malaysia, Mexico, Peru, Philippines, Poland, Rwanda, Thailand, United States and recycled or scrap sources
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Tungsten
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Australia, Austria, Bolivia, Brazil, Cambodia, Canada, China, Colombia, Indonesia, Mexico, Mongolia, Nigeria, Peru, Portugal, Russian Federation, Rwanda, Spain, Thailand, United States, Vietnam and recycled or scrap sources
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Gold
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Argentina, Australia, Belgium, Brazil, Canada, Chile, China, Ghana, Guyana, Indonesia, Japan, Kazakhstan, Kenya, Laos, Malaysia, Mexico, Papua New Guinea, Peru, Philippines, Russian Federation, South Africa, South Korea, South Africa, Spain, Suriname, Switzerland, Taiwan, Thailand, United Arab Emirates, United States and recycled or scrap sources
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Conflict Minerals Disclosure
This Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available at www.intc.com and www.intel.com/conflictfree as well as the SEC's EDGAR database at www.sec.gov.
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form SD.
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___________________
Intel, the Intel logo, and Ultrabook are trademarks of Intel Corporation in the U.S. and/or other countries.
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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 duly authorized undersigned.
INTEL CORPORATION
(Registrant)
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By:
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/s/ Brian M. Krzanich
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May 21, 2015
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Brian M. Krzanich
Chief Executive Officer
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Date
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6
Exhibit 1.01
Conflict Minerals Report
Intel Corporation
in accord with Rule 13p-1 under the Securities Exchange Act of 1934
This Conflict Minerals Report ("Report") of Intel Corporation ("Intel" or "we") for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended ("Rule"). Numerous terms in this Report are defined in the Rule and our Specialized Disclosure Report on Form SD and the reader is referred to those sources and to SEC Release No. 34-67716 issued by the Securities and Exchange Commission on August 22, 2012 for such definitions.
Pursuant to the Rule, we undertook due diligence measures on the source and chain of custody of the necessary conflict minerals in our products which we had reason to believe may have originated from the Democratic Republic of the Congo ("DRC") or an adjoining country (collectively defined as the "Covered Countries") and which may not have come from recycled or scrap sources, to determine whether such products were "DRC conflict free". The term "conflict free" is used in this Report in a broader sense to refer to suppliers, supply chains, smelters and refiners whose sources of conflict minerals did not or do not directly or indirectly finance or benefit armed groups in the Covered Countries.
Design of Conflict Minerals Program
The design of our conflict minerals program is in conformity with the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, "OECD Guidance"), specifically as it relates to our position in the minerals supply chain as a "downstream" purchaser. Summarized below are the design components of our conflict minerals program as they relate to the five-step framework from the OECD Guidance:
1.
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Maintain strong company management systems:
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Operate an internal "Conflict Minerals" team led by our Global Supply Management organization to implement our Conflict Minerals Sourcing Policy, which policy is included in our Form SD. Regularly review such implementation efforts with our Chief Executive Officer ("CEO") and senior management of our Technology and Manufacturing Group ("TMG").
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Employ a supply chain system of controls and transparency through the use of due diligence tools created by the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI)'s Conflict-Free Sourcing Initiative ("CFSI") which includes the Conflict Minerals Reporting Template ("CMRT"), a supply chain survey designed to identify the smelters and refiners that process the necessary conflict minerals contained in our products.
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Feature requirements related to conflict minerals in our standard template for supplier contracts and specifications so that current and future suppliers are obligated to comply with our policies on conflict minerals, including participation in a supply chain survey and related due diligence activities.
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Maintain records relating to our conflict minerals program in accordance with our record retention guidelines.
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Enable employees, suppliers and other stakeholders to report any concerns relating to our conflict minerals program through our online corporate responsibility reporting and grievance mechanism found on our conflict free website (www.intel.com/conflictfree).
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2.
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Identify and assess risks in our supply chain:
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Identify direct suppliers that supply products to Intel that may contain conflict minerals.
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Conduct a supply chain survey using the CMRT, requesting direct suppliers to identify smelters and refiners and country of origin of the conflict minerals in products they supply to Intel.
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Contact direct suppliers that do not respond to the supply chain survey by a specified date, requesting their responses.
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Compare smelters and refiners identified by the supply chain survey against the list of facilities that have received a "conflict free" designation from the Conflict Free Smelter Program ("CFSP") or other independent third party audit program such as the London Bullion Market Association's Responsible Gold Programme and the Responsible Jewellery Council's Chain-of-Custody Certification program, which designations provide country of origin and/or due diligence information on the conflict minerals sourced by such facilities.
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Document country of origin information for the smelters and refiners identified by the supply chain survey as provided from multiple sources including the supply chain survey, independent third party audit programs and directly from smelters and refiners that Intel contacts.
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3.
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Execute a strategy to respond to identified risks:
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Maintain a risk management plan that includes due diligence reviews of suppliers, smelters and refiners that may be sourcing or processing conflict minerals from the Covered Countries which may not be from recycled or scrap sources. Our due diligence measures are significantly based on multi-industry due diligence initiatives to evaluate the procurement practices of the smelters and refiners that process and provide those conflict minerals to our supply chain.
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Monitor and track suppliers, smelters and refiners identified as not meeting the requirements set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements.
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Perform risk mitigation efforts to bring suppliers into conformity with our Conflict Minerals Sourcing Policy and contractual requirements, which efforts may include working with direct suppliers to consider an alternative source for the necessary conflict minerals.
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Contact select smelter and refiner facilities that have not received a "conflict free" designation from an independent third party audit program to encourage their participation in such a program and request country of origin and chain of custody information.
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Provide progress reports to our CEO and TMG senior management summarizing our risk mitigation efforts.
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As required by the Rule, obtain an independent private sector audit of this Report.
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4.
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Support the development and implementation of independent third party audits of smelters' and refiners' sourcing:
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Support development and implementation of due diligence practices and tools such as the CMRT through our participation and leadership within the CFSI and CFSI sub-teams.
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Support development and implementation of the CFSP by writing the CFSP audit protocol and procedures in conjunction with CFSI member companies and other industry groups.
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Support independent third party audits of smelters and refiners such as the CFSP through our membership in and financial support of the CFSI.
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5.
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Report on supply chain due diligence:
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Publicly communicate our Conflict Minerals Sourcing Policy on our company website at www.intel.com/conflictfree.
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Report annually on our supply chain due diligence activities in our white paper titled "Intel's Efforts to Achieve a 'Conflict Free' Supply Chain" and Corporate Social Responsibility Report available on our company website at www.intel.com/conflictfree.
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The content of any website referred to in this Report is included for general information only and is not incorporated by reference in this Report.
Description of Due Diligence Measures Performed
Below is a description of the measures we performed for this reporting period to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products which we had reason to believe may have originated from the Covered Countries and may not have come from recycled or scrap sources:
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Conducted a supply-chain survey of suppliers which we identified may be supplying Intel with products that contain necessary conflict minerals using the CFSI's CMRT, requesting country of origin information regarding the necessary conflict minerals and identification of smelters and refiners that process such minerals.
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Received responses to the supply-chain survey request from approximately 99% of our surveyed suppliers.
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Contacted surveyed suppliers on responses to supply chain surveys that we identified contained incomplete or potentially inaccurate information to seek additional clarifying information.
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Compared smelters and refiners identified by the supply chain survey against the list of facilities that have received a "conflict free" designation from the CFSP or other independent third party audit program.
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Monitored and tracked suppliers, smelters and refiners identified as not meeting the requirements set forth in our Conflict Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements.
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Performed risk mitigation efforts with suppliers we identified to be not in conformity with our Conflict Minerals Sourcing Policy and contractual requirements by working with them to bring them into compliance.
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In 2014, visited eight smelters and refiners that had not received a "conflict free" designation to collect country of origin information and encourage and assist their participation in the CFSP or other independent third party audit program.
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Provided nine progress reports to TMG senior management and two progress reports to our CEO that summarized the status of our conflict minerals program including the compliance status of smelters and refiners in our supply chain.
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As required by the Rule, obtained an independent private sector audit of this Report, which is set forth as Exhibit A to this Report.
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Products
During this reporting period, we identified the following products which we manufactured or contracted with others to manufacture that may contain necessary conflict minerals (defined as any tantalum, tin, tungsten or gold that is necessary to the functionality or production of our products):
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"Client Microprocessors and Chipsets": Desktop and mobile microprocessors and chipsets that are solely manufactured by Intel, which are comprised of the following: Celeron®, Pentium®, Intel® Core™ M, Intel® Core i3™, Intel® Core™ i5, Intel® Core™ i7, Intel® Quark™, and Intel® Atom™ processors (except Intel® Atom™ processors for servers, storage and communications).
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"All Other": All other Intel® products that may contain necessary conflict minerals that we manufactured or contracted with others to manufacture, which products are comprised of the following:
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Server: Enterprise branded microprocessors, chipsets, motherboards, server and micro-server systems which contain components manufactured by Intel and other components purchased by Intel including Intel® Xeon Phi™, Intel® Xeon®, Itanium® and Intel® Atom™ processors for servers and storage.
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Mobile: Wireless platforms including Intel® mobile phone platforms and mobile communications platforms such as Intel® XMM™ slim modems.
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Networking: Ethernet network adapters, controllers and wireless products which enable the computers and networks to exchange data including Thunderbolt™ technology, Intel® Centrino® technology, Intel® WiMAX and Intel® WiFi products.
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Boards and Other Components: Desktop printed circuit boards and other components including Intel® Desktop Boards, Intel® Galileo boards, Intel® Edison boards, and Intel® NUC (next unit of computing).
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Storage and Other: Memory products including Intel® Solid-State Drives (Intel® SSDs) and Intel® Atom™ processors for storage and communications.
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Results of our Due Diligence Measures
Inherent Limitations on Due Diligence Measures:
As a downstream purchaser of products which contain conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by independent third party audit programs. Such sources of information, as well as our smelters and refiner facility visits, may yield inaccurate or incomplete information and may be subject to fraud.
Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. Under the Dodd-Frank Act and the Rule, a product is "DRC conflict free" if it meets the required standard every day of the reporting year; conversely, a product would "not be found to be DRC conflict free" if it does not meet the required standard even one day of the reporting year. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers and the entire supply-chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners. We ask that the data cover the entire reporting year, and we seek to use contract provisions requiring the suppliers to promptly update us in the event that the sourcing data changes.
Supply Chain Survey Responses
We conducted a supply-chain survey of the 324 direct suppliers that we identified may contribute necessary conflict minerals to our products. The overall response rate to this survey was approximately 99% compared to the 83% response rate attained in 2013; and 100% of our direct suppliers that contribute necessary conflict minerals to our Client Microprocessor and Chipset products responded to our 2014 supply chain survey. Our supplier requirements related to providing DRC conflict free products to Intel include:
1.
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publish a conflict mineral sourcing policy on the supplier's public website;
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2.
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participate annually in our conflict minerals supply-chain survey using the CMRT;
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3.
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accurately identify all smelters and refiners facilities which process the conflict minerals contained in the products provided to Intel; and
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4.
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verify the smelters or refiners which process the conflict minerals contained in the products provided to Intel have received a "conflict free" designation from the CFSP or other independent third party audit program.
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Smelter and Refiner Due Diligence Summary
In response to our supply-chain survey, our suppliers identified 229 operational smelter and refiner facilities which may process the necessary conflict minerals contained in the materials provided to Intel. Of those facilities, as of May 15, 2015:
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155 have received a "conflict free" designation from an independent third party audit program;
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42 have not yet received a "conflict free" designation but have begun participating in an independent third party audit program;
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the remaining facilities have not begun participating in an independent third party audit program;
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all tantalum smelters have received a "conflict free" designation from an independent third party audit program; and
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all smelters and refiners we believe may source conflict minerals from the Covered Countries have received a "conflict free" designation from an independent third party audit program.
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To our knowledge, none of these 229 facilities directly or indirectly finance or benefit armed groups in the Covered Countries.
Additional information regarding such smelter and refiner facilities is available in Table 1 below.
Product Determination
On the basis of our due diligence measures as described in this Report, we have concluded in good faith that during this reporting period, the necessary conflict minerals contained in our products that originated or may have originated from the Covered Countries are either DRC conflict free or DRC conflict undeterminable as described below.
DRC conflict free
Our Client Microprocessor and Chipset products are DRC conflict free. Our suppliers have identified the smelters and refiners in the supply chain that are sources of the necessary conflict minerals for our Client Microprocessor and Chipset products. All of these smelters and refiners have received a "conflict free" designation from the CFSP or other independent third party audit program which resulted in our reasonable determination that our Client Microprocessor and Chipset products are DRC conflict free.
DRC conflict undeterminable
All Other products are DRC conflict undeterminable. We are making this determination because we have insufficient information from suppliers or other sources regarding all of the smelters and refiners that processed the necessary conflict minerals in All Other products to conclude whether those conflict minerals originated in the Covered Countries and, if so, whether those conflict minerals were from recycled or scrap sources or other conflict free sources.
Our efforts to determine the mine or location of origin of the necessary conflict minerals in our products that are DRC conflict undeterminable with the greatest possible specificity consisted of the due diligence measures described in this Report. In particular, because independent third party audit programs validate whether sufficient evidence exists regarding country, mine and/or location of origin of the conflict minerals that the audited smelter or refiner facilities have processed, we relied on the information made available by such programs for the smelters and refiners in our supply chain. For smelters or refiners in our supply chain that had not received a "conflict free" designation by any independent third party audit programs, we attempted to contact such facilities to request country, mine and/or location of origin of the conflict minerals processed by them, and in certain cases, visited the facilities to perform an on-site review of this information. We were unable to ascertain the country of origin and/or chain of custody of all necessary conflict minerals processed by facilities that contribute to All Other products because, for this reporting period, certain smelter and refiner facilities (1) had not yet received a "conflict free" designation from an independent third party audit program, (2) did not respond to our requests for country of origin or chain of custody information, (3) were unwilling to allow us to visit the facility to conduct an on-site review of such information, or (4) did not have contact details available to establish communication to request country of origin or chain of custody information.
Table 1 below lists the facilities which, to the extent known, processed the necessary conflict minerals in All Other products.
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Metal
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Smelter or Refiner Facility Name†
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Location of Facility†
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Gold
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Aida Chemical Industries Co., Ltd. *
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Japan
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Gold
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Allgemeine Gold-und Silberscheideanstalt A.G. *
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Germany
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Gold
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Almalyk Mining and Metallurgical Complex (AMMC)
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Uzbekistan
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Gold
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AngloGold Ashanti Córrego do Sítio Mineração *
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Brazil
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Gold
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Argor-Heraeus SA *
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Switzerland
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Gold
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Asahi Pretec Corporation *
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Japan
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Gold
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Asaka Riken Co., Ltd.
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Japan
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Gold
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Atasay Kuyumculuk Sanayi Ve Ticaret A.S. *
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Turkey
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Gold
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Aurubis AG *
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Germany
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Gold
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Bangko Sentral ng Pilipinas (Central Bank of the Philippines) *
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Philippines
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Gold
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Bauer Walser AG
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Germany
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Gold
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Boliden AB *
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Sweden
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Gold
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C. Hafner GmbH + Co. KG *
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Germany
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Gold
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Caridad
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Mexico
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Gold
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CCR Refinery – Glencore Canada Corporation *
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Canada
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Metal
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Smelter or Refiner Facility Name†
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Location of Facility†
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Gold
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Cendres + Métaux SA
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Switzerland
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Gold
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Chimet S.p.A. *
|
Italy
|
|
|
Gold
|
Chugai Mining
|
Japan
|
|
|
Gold
|
Daejin Indus Co., Ltd.
|
South Korea
|
|
|
Gold
|
Daye Non-Ferrous Metals Mining Ltd.
|
China
|
|
|
Gold
|
Do Sung Corporation
|
South Korea
|
|
|
Gold
|
Doduco
|
Germany
|
|
|
Gold
|
Dowa *
|
Japan
|
|
|
Gold
|
Eco-System Recycling Co., Ltd. *
|
Japan
|
|
|
Gold
|
Gansu Seemine Material Hi-Tech Co., Ltd.
|
China
|
|
|
Gold
|
Guangdong Jinding Gold Limited
|
China
|
|
|
Gold
|
Hangzhou Fuchunjiang Smelting Co., Ltd.
|
China
|
|
|
Gold
|
Heimerle + Meule GmbH *
|
Germany
|
|
|
Gold
|
Heraeus Ltd. Hong Kong *
|
Hong Kong
|
|
|
Gold
|
Heraeus Precious Metals GmbH & Co. KG *
|
Germany
|
|
|
Gold
|
Hunan Chenzhou Mining Group Co., Ltd.
|
China
|
|
|
Gold
|
Hwasung CJ Co., Ltd.
|
South Korea
|
|
|
Gold
|
Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited
|
China
|
|
|
Gold
|
Ishifuku Metal Industry Co., Ltd. *
|
Japan
|
|
|
Gold
|
Istanbul Gold Refinery *
|
Turkey
|
|
|
Gold
|
Japan Mint *
|
Japan
|
|
|
Gold
|
Jiangxi Copper Company Limited
|
China
|
|
|
Gold
|
Johnson Matthey Inc. *
|
United States
|
|
|
Gold
|
Johnson Matthey Limited *
|
Canada
|
|
|
Gold
|
JSC Ekaterinburg Non-Ferrous Metal Processing Plant *
|
Russian Federation
|
|
|
Gold
|
JSC Uralelectromed *
|
Russian Federation
|
|
|
Gold
|
JX Nippon Mining & Metals Co., Ltd. *
|
Japan
|
|
|
Gold
|
Kazzinc *
|
Kazakhstan
|
|
|
Gold
|
Kennecott Utah Copper LLC *
|
United States
|
|
|
Gold
|
Kojima Chemicals Co., Ltd. *
|
Japan
|
|
|
Gold
|
Korea Metal Co., Ltd.
|
South Korea
|
|
|
Gold
|
Kyrgyzaltyn JSC
|
Kyrgyzstan
|
|
|
Gold
|
L' azurde Company For Jewelry *
|
Saudi Arabia
|
|
|
Gold
|
Lingbao Gold Company Limited
|
China
|
|
|
Gold
|
Lingbao Jinyuan Tonghui Refinery Co., Ltd.
|
China
|
|
|
Gold
|
LS-NIKKO Copper Inc. *
|
South Korea
|
|
|
Gold
|
Luoyang Zijin Yinhui Gold Refinery Co., Ltd.
|
China
|
|
|
Gold
|
Materion *
|
United States
|
|
|
Gold
|
Matsuda Sangyo Co., Ltd. *
|
Japan
|
|
|
Gold
|
Metalor Technologies (Hong Kong) Ltd. *
|
Hong Kong
|
|
|
Gold
|
Metalor Technologies (Singapore) Pte., Ltd. *
|
Singapore
|
|
|
Gold
|
Metalor Technologies SA *
|
Switzerland
|
|
|
Gold
|
Metalor USA Refining Corporation *
|
United States
|
|
|
Gold
|
METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V *
|
Mexico
|
|
|
Gold
|
Mitsubishi Materials Corporation *
|
Japan
|
|
|
Gold
|
Mitsui Mining and Smelting Co., Ltd. *
|
Japan
|
|
|
Gold
|
Moscow Special Alloys Processing Plant
|
Russian Federation
|
|
|
Gold
|
Nadir Metal Rafineri San. Ve Tic. A.Ş. *
|
Turkey
|
|
|
Gold
|
Navoi Mining and Metallurgical Combinat
|
Uzbekistan
|
|
|
Gold
|
Nihon Material Co., Ltd. *
|
Japan
|
|
|
Gold
|
Ohio Precious Metals, LLC *
|
United States
|
|
|
Gold
|
Ohura Precious Metal Industry Co., Ltd. *
|
Japan
|
|
|
Gold
|
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastvetmet) *
|
Russian Federation
|
|
|
Gold
|
OJSC Kolyma Refinery
|
Russian Federation
|
|
|
Gold
|
OJSC Novosibirsk Refinery
|
Russian Federation
|
|
|
Gold
|
PAMP SA *
|
Switzerland
|
|
|
Gold
|
Penglai Penggang Gold Industry Co., Ltd.
|
China
|
|
|
Gold
|
Prioksky Plant of Non-Ferrous Metals
|
Russian Federation
|
|
|
Gold
|
PT Aneka Tambang (Persero) Tbk *
|
Indonesia
|
|
|
Gold
|
PX Précinox SA *
|
Switzerland
|
|
|
Gold
|
Rand Refinery (Pty) Ltd. *
|
South Africa
|
|
|
Gold
|
Royal Canadian Mint *
|
Canada
|
|
|
Gold
|
Sabin Metal Corp.
|
United States
|
|
|
Gold
|
SAMWON Metals Corp.
|
South Korea
|
|
|
Gold
|
Schone Edelmetaal *
|
Netherlands
|
|
|
Gold
|
SEMPSA Joyería Platería SA *
|
Spain
|
|
|
Gold
|
Shandong Zhaojin Gold & Silver Refinery Co., Ltd. *
|
China
|
|
|
Metal
|
Smelter or Refiner Facility Name†
|
Location of Facility†
|
|
|
Gold
|
So Accurate Group, Inc.
|
United States
|
|
|
Gold
|
SOE Shyolkovsky Factory of Secondary Precious Metals
|
Russian Federation
|
|
|
Gold
|
Solar Applied Materials Technology Corp. *
|
Taiwan
|
|
|
Gold
|
Sumitomo Metal Mining Co., Ltd. *
|
Japan
|
|
|
Gold
|
Tanaka Kikinzoku Kogyo K.K. *
|
Japan
|
|
|
Gold
|
The Great Wall Gold and Silver Refinery of China
|
China
|
|
|
Gold
|
The Refinery of Shandong Gold Mining Co., Ltd. *
|
China
|
|
|
Gold
|
Tokuriki Honten Co., Ltd. *
|
Japan
|
|
|
Gold
|
Tongling Nonferrous Metals Group Co., Ltd.
|
China
|
|
|
Gold
|
Torecom
|
South Korea
|
|
|
Gold
|
Umicore Brasil Ltda. *
|
Brazil
|
|
|
Gold
|
Umicore Precious Metals Thailand *
|
Thailand
|
|
|
Gold
|
Umicore SA Business Unit Precious Metals Refining *
|
Belgium
|
|
|
Gold
|
United Precious Metal Refining, Inc. *
|
United States
|
|
|
Gold
|
Valcambi SA *
|
Switzerland
|
|
|
Gold
|
Western Australian Mint trading as The Perth Mint *
|
Australia
|
|
|
Gold
|
Yamamoto Precious Metal Co., Ltd. *
|
Japan
|
|
|
Gold
|
Yokohama Metal Co., Ltd.
|
Japan
|
|
|
Gold
|
Yunnan Copper Industry Co., Ltd.
|
China
|
|
|
Gold
|
Zhongyuan Gold Smelter of Zhongjin Gold Corporation *
|
China
|
|
|
Gold
|
Zijin Mining Group Co., Ltd. Gold Refinery *
|
China
|
|
|
Tantalum
|
Changsha South Tantalum Niobium Co., Ltd. *
|
China
|
|
|
Tantalum
|
Conghua Tantalum and Niobium Smeltry *
|
China
|
|
|
Tantalum
|
Duoluoshan *
|
China
|
|
|
Tantalum
|
Exotech Inc. *
|
United States
|
|
|
Tantalum
|
F&X Electro-Materials Ltd. *
|
China
|
|
|
Tantalum
|
Global Advanced Metals Aizu *
|
United States
|
|
|
Tantalum
|
Global Advanced Metals Boyertown *
|
United States
|
|
|
Tantalum
|
Guangdong Zhiyuan New Material Co., Ltd. *
|
China
|
|
|
Tantalum
|
Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch *
|
China
|
|
|
Tantalum
|
H.C. Starck Co., Ltd. *
|
Thailand
|
|
|
Tantalum
|
H.C. Starck GmbH Goslar *
|
Germany
|
|
|
Tantalum
|
H.C. Starck GmbH Laufenburg *
|
Germany
|
|
|
Tantalum
|
H.C. Starck Hermsdorf GmbH *
|
Germany
|
|
|
Tantalum
|
H.C. Starck Inc. *
|
United States
|
|
|
Tantalum
|
H.C. Starck Ltd. *
|
Japan
|
|
|
Tantalum
|
H.C. Starck Smelting GmbH & Co.KG *
|
Germany
|
|
|
Tantalum
|
Hengyang King Xing Lifeng New Materials Co., Ltd. *
|
China
|
|
|
Tantalum
|
Hi-Temp Specialty Metals, Inc. *
|
United States
|
|
|
Tantalum
|
JiuJiang JinXin Nonferrous Metals Co., Ltd. *
|
China
|
|
|
Tantalum
|
Jiujiang Tanbre Co., Ltd. *
|
China
|
|
|
Tantalum
|
KEMET Blue Metals *
|
Mexico
|
|
|
Tantalum
|
KEMET Blue Powder *
|
United States
|
|
|
Tantalum
|
King-Tan Tantalum Industry Ltd. *
|
China
|
|
|
Tantalum
|
LSM Brasil S.A. *
|
Brazil
|
|
|
Tantalum
|
Metallurgical Products India Pvt., Ltd. *
|
India
|
|
|
Tantalum
|
Mineração Taboca S.A. *
|
Brazil
|
|
|
Tantalum
|
Mitsui Mining & Smelting *
|
Japan
|
|
|
Tantalum
|
Molycorp Silmet A.S. *
|
Estonia
|
|
|
Tantalum
|
Ningxia Orient Tantalum Industry Co., Ltd. *
|
China
|
|
|
Tantalum
|
Plansee SE Liezen *
|
Austria
|
|
|
Tantalum
|
Plansee SE Reutte *
|
Austria
|
|
|
Tantalum
|
QuantumClean *
|
United States
|
|
|
Tantalum
|
RFH Tantalum Smeltry Co., Ltd. *
|
China
|
|
|
Tantalum
|
Solikamsk Magnesium Works OAO *
|
Russian Federation
|
|
|
Tantalum
|
Taki Chemicals *
|
Japan
|
|
|
Tantalum
|
Telex Metals *
|
United States
|
|
|
Tantalum
|
Ulba Metallurgical Plant JSC *
|
Kazakhstan
|
|
|
Tantalum
|
Yichun Jin Yang Rare Metal Co., Ltd. *
|
China
|
|
|
Tantalum
|
Zhuzhou Cemented Carbide *
|
China
|
|
|
Tin
|
Alpha *
|
United States
|
|
|
Tin
|
China Tin Group Co., Ltd.
|
China
|
|
|
Tin
|
CNMC (Guangxi) PGMA Co., Ltd.
|
China
|
|
|
Tin
|
Cooperativa Metalurgica de Rondônia Ltda. *
|
Brazil
|
|
|
Tin
|
CV Gita Pesona
|
Indonesia
|
|
|
Tin
|
CV Serumpun Sebalai
|
Indonesia
|
|
|
Tin
|
CV United Smelting *
|
Indonesia
|
|
|
Tin
|
Dowa *
|
Japan
|
|
|
Metal
|
Smelter or Refiner Facility Name†
|
Location of Facility†
|
|
|
Tin
|
EM Vinto *
|
Bolivia
|
|
|
Tin
|
Estanho de Rondônia S.A.
|
Brazil
|
|
|
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
|
Huichang Jinshunda Tin Co., Ltd.
|
China
|
|
|
Tin
|
Jiangxi Ketai Advanced Material Co., Ltd. *
|
China
|
|
|
Tin
|
Linwu Xianggui Ore Smelting 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
|
Metallo-Chimique N.V. *
|
Belgium
|
|
|
Tin
|
Mineração Taboca S.A. *
|
Brazil
|
|
|
Tin
|
Minsur *
|
Peru
|
|
|
Tin
|
Mitsubishi Materials Corporation *
|
Japan
|
|
|
Tin
|
Novosibirsk Processing Plant Ltd.
|
Russian Federation
|
|
|
Tin
|
O.M. Manufacturing (Thailand) Co., Ltd.
|
Thailand
|
|
|
Tin
|
O.M. Manufacturing Philippines, Inc. *
|
Philippines
|
|
|
Tin
|
Operaciones Metalurgical S.A. *
|
Bolivia
|
|
|
Tin
|
PT Aries Kencana Sejahtera
|
Indonesia
|
|
|
Tin
|
PT Artha Cipta Langgeng *
|
Indonesia
|
|
|
Tin
|
PT ATD Makmur Mandiri Jaya *
|
Indonesia
|
|
|
Tin
|
PT Babel Inti Perkasa *
|
Indonesia
|
|
|
Tin
|
PT Bangka Putra Karya *
|
Indonesia
|
|
|
Tin
|
PT Bangka Tin Industry *
|
Indonesia
|
|
|
Tin
|
PT Belitung Industri Sejahtera *
|
Indonesia
|
|
|
Tin
|
PT BilliTin Makmur Lestari
|
Indonesia
|
|
|
Tin
|
PT Bukit Timah *
|
Indonesia
|
|
|
Tin
|
PT DS Jaya Abadi *
|
Indonesia
|
|
|
Tin
|
PT Eunindo Usaha Mandiri *
|
Indonesia
|
|
|
Tin
|
PT Inti Stania Prima *
|
Indonesia
|
|
|
Tin
|
PT JusTindo
|
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 Sariwiguna Binasentosa *
|
Indonesia
|
|
|
Tin
|
PT Seirama Tin Investment
|
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
|
|
|
Tin
|
Rui Da Hung
|
Taiwan
|
|
|
Tin
|
Soft Metais Ltda. *
|
Brazil
|
|
|
Tin
|
Thaisarco *
|
Thailand
|
|
|
Tin
|
White Solder Metalurgia e Mineração Ltda. *
|
Brazil
|
|
|
Tin
|
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
|
China
|
|
|
Tin
|
Yunnan Tin Group (Holding) Company Limited *
|
China
|
|
|
Tungsten
|
A.L.M.T. TUNGSTEN Corp.
|
Japan
|
|
|
Tungsten
|
Chenzhou Diamond Tungsten Products Co., Ltd. *
|
China
|
|
|
Tungsten
|
Chongyi Zhangyuan Tungsten Co., Ltd.
|
China
|
|
|
Tungsten
|
Dayu Weiliang Tungsten Co., Ltd.
|
China
|
|
|
Tungsten
|
Fujian Jinxin Tungsten Co., Ltd. *
|
China
|
|
|
Tungsten
|
Ganzhou Huaxing Tungsten Products Co., Ltd. *
|
China
|
|
|
Tungsten
|
Ganzhou Non-ferrous Metals Smelting Co., Ltd.
|
China
|
|
|
Tungsten
|
Ganzhou Seadragon W & Mo Co., Ltd. *
|
China
|
|
|
Tungsten
|
Global Tungsten & Powders Corp. *
|
United States
|
|
|
Tungsten
|
Guangdong Xianglu Tungsten Co., Ltd.
|
China
|
|
|
Tungsten
|
H.C. Starck GmbH
|
Germany
|
|
|
Tungsten
|
H.C. Starck Smelting GmbH & Co.KG
|
Germany
|
|
|
Tungsten
|
Hunan Chenzhou Mining Group Co., Ltd.
|
China
|
|
|
Tungsten
|
Hunan Chunchang Nonferrous Metals Co., Ltd. *
|
China
|
|
|
Tungsten
|
Hydrometallurg, JSC
|
Russian Federation
|
|
|
Tungsten
|
Japan New Metals Co., Ltd. *
|
Japan
|
|
|
Tungsten
|
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
|
China
|
|
|
Metal
|
Smelter or Refiner Facility Name†
|
Location of Facility†
|
|
|
Tungsten
|
Jiangxi Gan Bei Tungsten Co., Ltd. *
|
China
|
|
|
Tungsten
|
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
|
China
|
|
|
Tungsten
|
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
|
China
|
|
|
Tungsten
|
Kennametal Huntsville
|
United States
|
|
|
Tungsten
|
Malipo Haiyu Tungsten Co., Ltd. *
|
China
|
|
|
Tungsten
|
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
|
Vietnam
|
|
|
Tungsten
|
Tejing (Vietnam) Tungsten Co., Ltd.
|
Vietnam
|
|
|
Tungsten
|
Wolfram Bergbau und Hütten AG *
|
Austria
|
|
|
Tungsten
|
Xiamen Tungsten (H.C.) Co., Ltd. *
|
China
|
|
|
Tungsten
|
Xiamen Tungsten Co., Ltd. *
|
China
|
|
|
Tungsten
|
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
|
China
|
|
|
Countries of origin of the conflict minerals these facilities may process include:
Angola, Argentina, Australia, Austria, Belgium, Bolivia, Brazil, Burundi, Canada, Central African Republic, Chile, China, Colombia, Cote D'Ivoire, Czech Republic, Djibouti, DRC, Egypt, Estonia, Ethiopia, France, Germany, Ghana, Guyana, Hungary, India, Indonesia, Ireland, Israel, Japan, Kazakhstan, Kenya, Laos People's Democratic Republic, Luxembourg, Madagascar, Malaysia, Mongolia, Myanmar, Mozambique, Namibia, Netherlands, Nigeria, Peru, Portugal, Republic of Congo, Russian Federation, Rwanda, Sierra Leone, Singapore, Slovakia, South Korea, South Africa, Spain, South Sudan, Suriname, Switzerland, Taiwan, United Republic of Tanzania, Thailand, Uganda, United Arab Emirates, United Kingdom, United States, Uruguay, Vietnam, Zimbabwe
|
|
†
|
|
Smelter and refiner facility names and locations as reported by the CFSI as of May 15, 2015.
|
|
|
|
*
|
|
Denotes smelters and refiners which have received a "conflict free" designation from an independent third party audit program as of May 15, 2015.
|
Future Due Diligence Measures
During the reporting period for the calendar year ending December 31, 2015, we are continuing to engage in the activities described above in "Design of Conflict Minerals Program" and "Description of Due Diligence Measures Performed." In our efforts to attain a conflict free supply chain for our products, we intend to continue to contact smelters and refiners identified in our supply chain survey process that have not yet received a "conflict free" designation and request their participation in the CFSP or other independent third party audit program in order for them to obtain such a "conflict free" designation.
Independent Private Sector Audit of this Report
We obtained an independent private sector audit of this Report by Ernst & Young LLP, which is set forth as Exhibit A to this Report.
____________________________
Intel and the Intel logo, Intel Atom, Intel Core, Intel Xeon, Intel Xeon Phi, Centrino, Celeron, Itanium, Pentium, Quark, Thunderbolt, and XMM are trademarks of Intel Corporation in the U.S. and/or other countries.
Exhibit A
Report of Independent Accountants
Board of Directors and Stockholders of Intel Corporation
We have examined whether the design of Intel Corporation's (the "Company") due diligence framework as set forth in the Design of Conflict Minerals Program section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2014, is in conformity, in all material respects, with the criteria set forth in the Organisation of Economic Co-Operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition 2013 ("OECD Due Diligence Guidance"), and whether the Company's description of the due diligence measures it performed, as set forth in Description of Due Diligence Measures Performed section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2014, is consistent, in all material respects, with the due diligence process that the Company undertook.
Management is responsible for the design of the Company's due diligence framework and the description of the Company's due diligence measures set forth in the Conflict Minerals Report, and performance of the due diligence measures. Our responsibility is to express an opinion on the design of the Company's due diligence framework and on the description of the due diligence measures the Company performed, based on our examination. Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants and the standards applicable to attestation engagements contained in Government Auditing Standards, issued by the Comptroller General of the United States, and, accordingly, included examining, on a test basis, evidence about the design of the Company's due diligence framework and the description of the due diligence measures the Company performed, and performing such other procedures as we considered necessary in the circumstances. We believe that our examination provides a reasonable basis for our opinion.
Our examination was not conducted for the purpose of evaluating:
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The consistency of the due diligence measures that the Company performed with either the design of the Company's due diligence framework or the OECD Due Diligence Guidance
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The completeness of the Company's description of the due diligence measures performed
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The suitability of the design or operating effectiveness of the Company's due diligence process
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Whether a third party can determine from the Conflict Minerals Report if the due diligence measures the Company performed are consistent with the OECD Due Diligence Guidance
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The Company's reasonable country of origin inquiry (RCOI), including the suitability of the design of the RCOI, its operating effectiveness, or the results thereof
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The Company's conclusions about the source or chain of custody of its conflict minerals, those products subject to due diligence, or the DRC Conflict Free status of its products
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Accordingly, we do not express an opinion or any other form of assurance on the aforementioned matters or any other matters included in any section of the Conflict Minerals Report other than the design of the Company's due diligence framework as set forth in the Design of Conflict Minerals Program section and the Company's description of the due diligence measures it performed, as set forth in the Description of Due Diligence Measures Performed section referenced in the first paragraph above.
In our opinion, the design of the Company's due diligence framework for the reporting period from January 1 to December 31, 2014, as set forth in the Design of Conflict Minerals Program section of the Conflict Minerals Report is in conformity, in all material respects, with the OECD Due Diligence Guidance, and the Company's description of the due diligence measures it performed as set forth in the Description of Due Diligence Measures Performed section of the Conflict Minerals Report for the reporting period from January 1 to December 31, 2014, is consistent, in all material respects, with the due diligence process that the Company undertook.
/s/ Ernst & Young LLP
San Jose, California
May 21, 2015