UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
BLACKBERRY LIMITED
(Exact name of the registrant as specified in its charter)
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A6 | | 000-29898 | | 98-0164498 |
(State or other jurisdiction of incorporation or organization) | | (Commission File Number) | | (IRS Employer Identification No.) |
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2200 University Avenue East Waterloo, Ontario, Canada | | | | N2K 0A7 |
(Address of principal executive offices) | | | | (Zip code) |
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Steven E. Zipperstein | | | | (519) 597-7750 |
(Name and telephone number, including area code, of the person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
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_√__ | 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
Devices and accessories manufactured by or on behalf of BlackBerry Limited (“BlackBerry”) in 2014 contain conflict minerals that are necessary to their functionality or production. BlackBerry did not source these conflict minerals directly. These conflict minerals were processed and manufactured into components by suppliers, and sub-tier suppliers of BlackBerry, and subsequently assembled into devices and accessories via BlackBerry’s manufacturing facility or an electronics manufacturing services provider, original design manufacturer or accessory supplier.
BlackBerry continues to recognize its shared responsibility in relation to the responsible mining and sourcing of minerals in conflict-affected regions of the world, including the Democratic Republic of Congo and its neighboring countries. In early 2012, BlackBerry first adopted and published its Responsible Minerals Policy, consistent with its existing Supplier Code of Conduct and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. In 2014, BlackBerry made enhancements to its Responsible Minerals Policy, which further exemplifies its commitment to responsible sourcing. The policy is available at: http://us.blackberry.com/company/about-us/corporate-responsibility/supply-chain.html and establishes expectations within its supply chain that creates demand for responsibly sourced minerals used in BlackBerry products.
Section 1 - Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
Conflict Minerals Disclosure
BlackBerry has concluded in good faith that during the reporting period from January 1 to December 31, 2014,
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i) | it has manufactured, or contracted to manufacture, products in which “conflict minerals” (as defined in Section 1, Item 1.01 (d)(3) of Form SD) are necessary to the functionality or production of such products; and |
ii) based on a “reasonable country of origin inquiry”:
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a) | a portion of its necessary conflict minerals did originate or may have originated in the Democratic Republic of the Congo or an adjoining country (collectively referred to as the “Covered Countries”) and it knows or has reason to believe that those necessary conflict minerals may not be from recycle or scrap sources; and |
b) a portion of its necessary conflict minerals have an unknown origin.
BlackBerry’s reasonable country of origin inquiry included a combination of measures to determine whether the necessary conflict minerals in BlackBerry’s products originated from the Covered Countries. BlackBerry’s primary means of determining the country of origin of necessary conflict minerals is based on the surveying of relevant, direct suppliers. Considering its remote position in the supply chain relative to the processors of conflict minerals, BlackBerry is very reliant on these survey results received from suppliers, representing approximately 92% of BlackBerry’s total direct procurement activities by expenditure, to complete the reasonable country of origin inquiry and support subsequent due diligence.
The survey results include the identities of the processors of conflict minerals necessary to the functionality or production of the component parts or accessories manufactured by BlackBerry suppliers. BlackBerry then compared the identified processors (smelters or refiners) to the Conflict Free Sourcing Initiative’s (CFSI) Compliant Smelter Detailed Sourcing Information Report to determine if the processors are sourcing conflict minerals which originated in the Covered Countries.
Some suppliers have included country of origin information with their survey responses. Additional country of origin information was also available to BlackBerry through BlackBerry’s support for in-region sourcing programs such as Solutions for Hope and the Conflict-free Tin Initiative (more information available at: http://solutions-network.org/site-solutionsforhope and http://solutions-network.org/site-cfti/, respectively), and BlackBerry’s direct engagement of smelters and refiners.
Subsequent to the above determination, BlackBerry has filed a Conflict Minerals Report as Exhibit 1.01 hereto, which is publicly available at http://ca.blackberry.com/company/investors/corporate-governance.html.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 - Conflict Minerals Report for the period January 1 to December 31, 2014, as required by Items 1.01 and 1.02 of this Form.
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SIGNATURES
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.
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BLACKBERRY LIMITED | | | |
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By: | /s/ Steven E. Zipperstein | | Date: June 1, 2015 | |
Name: | Steven E. Zipperstein | | | |
Title: | Chief Legal Officer | | | |
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BlackBerry Limited
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM
JANUARY 1 TO DECEMBER 31, 2014
INTRODUCTION
This Conflict Minerals Report for BlackBerry Limited (“BlackBerry”, “Company,” “we,” or “our”) is provided in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”) for the reporting period from January 1 to December 31, 2014.
The Rule imposes certain reporting obligations on U.S Securities and Exchange Commission (“SEC”) registrants whose manufactured products contain tin, tantalum, tungsten, or gold (defined by the Rule as “conflict minerals”), that are necessary to the functionality or production of those products. If the SEC registrant has reason to believe that any of those conflict minerals may have originated in the Democratic Republic of the Congo or an adjoining country (“Covered Countries”), or is unable to determine the country of origin of those conflict minerals, the SEC registrant is required to submit a Conflict Minerals Report to the SEC that includes a description of the measures it took to exercise due diligence on the conflict minerals’ source and chain of custody.
Devices and accessories manufactured by or on behalf of BlackBerry in 2014 contain conflict minerals that are necessary to their functionality or production (“necessary conflict minerals”). BlackBerry did not source these conflict minerals directly. These conflict minerals were processed and manufactured into components by suppliers, and sub-tier suppliers of BlackBerry, and subsequently assembled into devices and accessories via BlackBerry’s manufacturing facility or an electronics manufacturing services provider, original design manufacturer or accessory supplier.
For the reporting period from January 1 to December 31, 2014, BlackBerry conducted a reasonable country of origin inquiry (“RCOI”). A brief description of BlackBerry’s RCOI is included in Form SD. The results of our RCOI were as follows:
a) a portion of our necessary conflict minerals did originate or may have originated in a Covered Country and we know or have reason to believe that those necessary conflict minerals may not be from recycle or scrap sources; and
b) a portion of our necessary conflict minerals have an unknown origin.
The statements below are based on the due diligence activities performed to date and in good faith by BlackBerry and are based on the information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters, evolving definition and confirmation of smelters, incomplete information from industry or other third-party sources and other items.
DUE DILIGENCE MEASURES
We conducted due diligence on the source and chain of custody of the necessary conflict minerals contained in products that we manufactured or contracted to manufacture as described above to ascertain whether these minerals originated in a Covered Country and directly or indirectly financed or benefited non-state armed groups in any of these countries.
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Design of Our Due Diligence Measures Our conflict minerals due diligence measures have been designed to conform 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 (2013) (the “OECD Guidance”), as applicable for tin, tantalum, tungsten and gold and for downstream companies (as the term is defined in the OECD Guidance), in all relevant material respects. With consideration of our position in the supply chain, we designed our due diligence measures in accordance with the five steps in the OECD Guidance to: 1. establish strong company management systems for conflict minerals supply chain due diligence; 2. identify and assess conflict minerals risks in our supply chain; 3. design and implement strategies to respond to conflict minerals risks identified; 4. contribute to independent third-party audits of the due diligence practices of conflict minerals smelters and refiners by participating in industry organizations; and 5. report on our conflict minerals supply chain due diligence activities. |
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Due Diligence Measures Performed BlackBerry’s due diligence measures during, and in support of, the reporting year included the following activities:
Step 1: Establish strong company management systems for conflict minerals supply chain due diligence 1) Revised our Responsible Minerals Policy, first published in 2012, by expanding upon BlackBerry’s program and strengthening our supplier expectations for responsible sourcing; 2) Maintained an internal team to advance BlackBerry’s Conflict Minerals Program and implement our Responsible Minerals Policy; 3) Continued implementation of standard contract language requiring supplier conformance to the BlackBerry Responsible Minerals Policy for incorporation into all new supply agreements; and 4) Maintained records associated with the implementation of BlackBerry’s due diligence process in accordance with specified requirements (minimum 5 year retention).
Step 2: Identify and assess risk in the supply chain 5) Identified relevant suppliers with the potential for providing materials, components, subassemblies, or finished goods containing at least of one of the necessary conflict minerals; 6) Notified relevant suppliers of necessary conflict minerals of our revised Responsible Minerals Policy and requested completion of the Conflict Free Sourcing Initiative (the “CFSI”) Conflict Minerals Reporting Template (“CMRT”), version 3.0 or later, to obtain updated sourcing and conflict minerals due diligence information about BlackBerry’s supply chain, including the identification of smelters and refiners in the supply chains of BlackBerry’s suppliers; 7) Reviewed supplier CMRT submissions for completeness and data credibility based on established criteria; and 8) Used the information submitted by suppliers in the CMRT to conduct an RCOI as described in BlackBerry’s Form SD report.
Step 3: Design and implement a strategy to respond to identified risks 9) Escalated the identities of suppliers who failed to provide credible sourcing data to BlackBerry commodity management; and 10) Provided due diligence guidance and communicated issues based on risk assessments in Step 2 to relevant first-tier suppliers.
Step 4: Carry out independent third-party audit of due diligence practices 11) Relied upon the due diligence conducted on smelters and refiners by the CFSI’s Conflict-Free Smelter Program (the “CFSP”). The CFSP uses independent private sector auditors to audit the source, including mines of origin and chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the CFSP. The smelters and refiners that are found to be CFSP compliant are those for which the independent auditor has verified that the smelters and refiners have demonstrated responsible minerals sourcing and implemented systems in compliance with CFSP requirements; and 12) Maintained an active membership in the CFSI and supported expansion of the CFSP to additional smelters and refiners by conducting the following actions: a. Led CFSI workgroup to maintain and enhance the CMRT; b. Contributed to CFSI activities to identify and engage new smelters and refiners; c. Submitted letters of support to smelters and refiners to encourage their participation in the CFSP; and d. Communicated with smelters and refiners to introduce the CFSP and prepare them for the CFSP audit.
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Step 5: Report on supply chain due diligence
13) As required under Section 13(p) of the Securities and Exchange Act of 1934, BlackBerry has filed a Form SD which includes this Conflict Minerals Report and made such information available on our website, demonstrating our progress in implementing our Responsible Minerals Policy.
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Independent Private Sector Audit
This Conflict Minerals Report has not been subject to an independent private sector audit (“IPSA”). Per guidance issued by the SEC on April 29, 2014 and the related order subsequently issued on May 2, 2014, only issuers who describe their products as “DRC conflict free” are subject to an IPSA.
DUE DILIGENCE DETERMINATION
On the basis of the due diligence measures detailed above, which are on the source and chain of custody of the conflict minerals in BlackBerry’s products, BlackBerry describes the following products as “DRC Conflict Undeterminable”*:
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Product Category |
BlackBerry’s Device and Accessory products |
*DRC conflict undeterminable products are those for which we were unable to determine that such products do not directly or indirectly finance or benefit armed groups in Covered Countries.
Facilities Processing Conflict Minerals
The facilities verified by the CFSI as “smelters” or “refiners”, which have been reported by BlackBerry suppliers as processing conflict minerals, are listed in Table 1.
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Table 1: List of Facilities Processing Conflict Minerals |
Conflict Mineral | Name of Smelter or Refiner Processing Conflict Mineral | Conflict-Free Status** |
Gold | Advanced Chemical Company | Unknown |
Gold | Aida Chemical Industries Co. Ltd. | DRC Conflict-Free |
Gold | Aktyubinsk Copper Company TOO | Unknown |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | DRC Conflict-Free |
Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Unknown |
Gold | AngloGold Ashanti Córrego do Sítio Mineração | DRC Conflict-Free |
Gold | Argor-Heraeus SA | DRC Conflict-Free |
Gold | Asahi Pretec Corporation | DRC Conflict-Free |
Gold | Asaka Riken Co Ltd | Unknown |
Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | DRC Conflict-Free |
Gold | Aurubis AG | DRC Conflict-Free |
Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Unknown |
Gold | Bauer Walser AG | Unknown |
Gold | Boliden AB | DRC Conflict-Free |
Gold | C. Hafner GmbH + Co. KG | DRC Conflict-Free |
Gold | Caridad | Unknown |
Gold | CCR Refinery - Glencore Canada Corporation | DRC Conflict-Free |
Gold | Cendres + Métaux SA | Unknown |
Gold | Chimet S.p.A. | DRC Conflict-Free |
Gold | Chugai Mining | Unknown |
Gold | Daejin Indus Co. Ltd | Unknown |
Gold | Daye Non-Ferrous Metals Mining Ltd. | Unknown |
Gold | Do Sung Corporation | Unknown |
Gold | Doduco | Unknown |
Gold | Dowa | DRC Conflict-Free |
Gold | Eco-System Recycling Co., Ltd. | DRC Conflict-Free |
Gold | FAGGI ENRICO SPA | Unknown |
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Gold | Gansu Seemine Material Hi-Tech Co Ltd | Unknown |
Gold | Geib Refining Corporation | Unknown |
Gold | Guangdong Jinding Gold Limited | Unknown |
Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | Unknown |
Gold | Heimerle + Meule GmbH | DRC Conflict-Free |
Gold | Heraeus Ltd. Hong Kong | DRC Conflict-Free |
Gold | Heraeus Precious Metals GmbH & Co. KG | DRC Conflict-Free |
Gold | Hunan Chenzhou Mining Group Co., Ltd. | Unknown |
Gold | Hwasung CJ Co. Ltd | Unknown |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | Unknown |
Gold | Ishifuku Metal Industry Co., Ltd. | DRC Conflict-Free |
Gold | Istanbul Gold Refinery | DRC Conflict-Free |
Gold | Japan Mint | DRC Conflict-Free |
Gold | Jiangxi Copper Company Limited | Unknown |
Gold | Johnson Matthey Inc | DRC Conflict-Free |
Gold | Johnson Matthey Ltd | DRC Conflict-Free |
Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | DRC Conflict-Free |
Gold | JSC Uralelectromed | Unknown |
Gold | JX Nippon Mining & Metals Co., Ltd. | DRC Conflict-Free |
Gold | Kazzinc | DRC Conflict-Free |
Gold | Kennecott Utah Copper LLC | DRC Conflict-Free |
Gold | Kojima Chemicals Co., Ltd | DRC Conflict-Free |
Gold | Korea Metal Co. Ltd | Unknown |
Gold | Kyrgyzaltyn JSC | Unknown |
Gold | L' azurde Company For Jewelry | DRC Conflict-Free |
Gold | Lingbao Gold Company Limited | Unknown |
Gold | Lingbao Jinyuan Tonghui Refinery Co. Ltd. | Unknown |
Gold | LS-NIKKO Copper Inc. | DRC Conflict-Free |
Gold | Materion | DRC Conflict-Free |
Gold | Matsuda Sangyo Co., Ltd. | DRC Conflict-Free |
Gold | Metalor Technologies (Hong Kong) Ltd | DRC Conflict-Free |
Gold | Metalor Technologies (Singapore) Pte. Ltd. | DRC Conflict-Free |
Gold | Metalor Technologies (Suzhou) Ltd. | Unknown |
Gold | Metalor Technologies SA | DRC Conflict-Free |
Gold | Metalor USA Refining Corporation | DRC Conflict-Free |
Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | DRC Conflict-Free |
Gold | Mitsubishi Materials Corporation | DRC Conflict-Free |
Gold | Mitsui Mining and Smelting Co., Ltd. | DRC Conflict-Free |
Gold | Moscow Special Alloys Processing Plant | Unknown |
Gold | Nadir Metal Rafineri San. Ve Tic. A.ª. | DRC Conflict-Free |
Gold | Navoi Mining and Metallurgical Combinat | Unknown |
Gold | Nihon Material Co. LTD | DRC Conflict-Free |
Gold | Ohio Precious Metals, LLC | DRC Conflict-Free |
Gold | Ohura Precious Metal Industry Co., Ltd | DRC Conflict-Free |
Gold | OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) | DRC Conflict-Free |
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Gold | OJSC Kolyma Refinery | Unknown |
Gold | OJSC Novosibirsk Refinery | Unknown |
Gold | PAMP SA | DRC Conflict-Free |
Gold | Penglai Penggang Gold Industry Co Ltd | Unknown |
Gold | Prioksky Plant of Non-Ferrous Metals | Unknown |
Gold | PT Aneka Tambang (Persero) Tbk | DRC Conflict-Free |
Gold | PX Précinox SA | DRC Conflict-Free |
Gold | Rand Refinery (Pty) Ltd | DRC Conflict-Free |
Gold | Republic Metals Corporation | DRC Conflict-Free |
Gold | Royal Canadian Mint | DRC Conflict-Free |
Gold | Sabin Metal Corp. | Unknown |
Gold | Samduck Precious Metals | Unknown |
Gold | SAMWON METALS Corp. | Unknown |
Gold | Schone Edelmetaal | DRC Conflict-Free |
Gold | SEMPSA Joyería Platería SA | DRC Conflict-Free |
Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | Unknown |
Gold | Shandong Zhaojin Gold & Silver Refinery Co. Ltd | DRC Conflict-Free |
Gold | So Accurate Group, Inc. | Unknown |
Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | Unknown |
Gold | Solar Applied Materials Technology Corp. | DRC Conflict-Free |
Gold | Sumitomo Metal Mining Co., Ltd. | DRC Conflict-Free |
Gold | Tanaka Kikinzoku Kogyo K.K. | DRC Conflict-Free |
Gold | The Great Wall Gold and Silver Refinery of China | Unknown |
Gold | The Refinery of Shandong Gold Mining Co. Ltd | DRC Conflict-Free |
Gold | Tokuriki Honten Co., Ltd | DRC Conflict-Free |
Gold | Tongling nonferrous Metals Group Co.,Ltd | Unknown |
Gold | Torecom | Unknown |
Gold | Umicore Brasil Ltda | DRC Conflict-Free |
Gold | Umicore Precious Metals Thailand | DRC Conflict-Free |
Gold | Umicore SA Business Unit Precious Metals Refining | DRC Conflict-Free |
Gold | United Precious Metal Refining, Inc. | DRC Conflict-Free |
Gold | Valcambi SA | DRC Conflict-Free |
Gold | Western Australian Mint trading as The Perth Mint | DRC Conflict-Free |
Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | Unknown |
Gold | Yokohama Metal Co Ltd | Unknown |
Gold | Yunnan Copper Industry Co Ltd | Unknown |
Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | Unknown |
Gold | Zijin Mining Group Co., Ltd. Gold Refinery | Unknown |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | DRC Conflict-Free |
Tantalum | Conghua Tantalum and Niobium Smeltry | DRC Conflict-Free |
Tantalum | Duoluoshan | DRC Conflict-Free |
Tantalum | Exotech Inc. | DRC Conflict-Free |
Tantalum | F&X Electro-Materials Ltd. | DRC Conflict-Free |
Tantalum | Global Advanced Metals Aizu | DRC Conflict-Free |
Tantalum | Global Advanced Metals Boyertown | DRC Conflict-Free |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | DRC Conflict-Free |
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Tantalum | Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch | DRC Conflict-Free |
Tantalum | H.C. Starck Co., Ltd. | DRC Conflict-Free |
Tantalum | H.C. Starck GmbH Goslar | DRC Conflict-Free |
Tantalum | H.C. Starck GmbH Laufenburg | DRC Conflict-Free |
Tantalum | H.C. Starck Hermsdorf GmbH | DRC Conflict-Free |
Tantalum | H.C. Starck Inc. | DRC Conflict-Free |
Tantalum | H.C. Starck Ltd. | DRC Conflict-Free |
Tantalum | H.C. Starck Smelting GmbH & Co.KG | DRC Conflict-Free |
Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | DRC Conflict-Free |
Tantalum | Hi-Temp Specialty Metals, Inc. | DRC Conflict-Free |
Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | DRC Conflict-Free |
Tantalum | Jiujiang Tanbre Co., Ltd. | DRC Conflict-Free |
Tantalum | KEMET Blue Metals | DRC Conflict-Free |
Tantalum | KEMET Blue Powder | DRC Conflict-Free |
Tantalum | King-Tan Tantalum Industry Ltd | DRC Conflict-Free |
Tantalum | LSM Brasil S.A. | DRC Conflict-Free |
Tantalum | Metallurgical Products India (Pvt.) Ltd. | DRC Conflict-Free |
Tantalum | Mineração Taboca S.A. | DRC Conflict-Free |
Tantalum | Mitsui Mining & Smelting | DRC Conflict-Free |
Tantalum | Molycorp Silmet A.S. | DRC Conflict-Free |
Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | DRC Conflict-Free |
Tantalum | Plansee SE Liezen | DRC Conflict-Free |
Tantalum | Plansee SE Reutte | DRC Conflict-Free |
Tantalum | QuantumClean | DRC Conflict-Free |
Tantalum | RFH Tantalum Smeltry Co., Ltd | DRC Conflict-Free |
Tantalum | Solikamsk Magnesium Works OAO | DRC Conflict-Free |
Tantalum | Taki Chemicals | DRC Conflict-Free |
Tantalum | Telex Metals | DRC Conflict-Free |
Tantalum | Ulba Metallurgical Plant JSC | DRC Conflict-Free |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd | DRC Conflict-Free |
Tantalum | Zhuzhou Cement Carbide | DRC Conflict-Free |
Tin | Alpha | DRC Conflict-Free |
Tin | China Tin Group Co., Ltd. | Unknown |
Tin | CNMC (Guangxi) PGMA Co. Ltd. | Unknown |
Tin | Cooperativa Metalurgica de Rondônia Ltda. | Unknown |
Tin | CV Gita Pesona | Unknown |
Tin | CV Serumpun Sebalai | Unknown |
Tin | CV United Smelting | DRC Conflict-Free |
Tin | Dowa | DRC Conflict-Free |
Tin | EM Vinto | DRC Conflict-Free |
Tin | Estanho de Rondônia S.A. | Unknown |
Tin | Feinhütte Halsbrücke GmbH | Unknown |
Tin | Fenix Metals | Unknown |
Tin | Gejiu Kai Meng Industry and Trade LLC | Unknown |
Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | DRC Conflict-Free |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | Unknown |
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Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | Unknown |
Tin | Huichang Jinshunda Tin Co. Ltd | Unknown |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | DRC Conflict-Free |
Tin | Linwu Xianggui Ore Smelting Co., Ltd. | Unknown |
Tin | Magnu's Minerais Metais e Ligas LTDA | DRC Conflict-Free |
Tin | Malaysia Smelting Corporation (MSC) | DRC Conflict-Free |
Tin | Melt Metais e Ligas S/A | DRC Conflict-Free |
Tin | Metallic Resources Inc | Unknown |
Tin | Metallo Chimique | DRC Conflict-Free |
Tin | Mineração Taboca S.A. | DRC Conflict-Free |
Tin | Minsur | DRC Conflict-Free |
Tin | Mitsubishi Materials Corporation | DRC Conflict-Free |
Tin | Nankang Nanshan Tin Manufactory Co., Ltd | Unknown |
Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Unknown |
Tin | Novosibirsk Processing Plant Ltd. | Unknown |
Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Unknown |
Tin | O.M. Manufacturing Philippines, Inc. | Unknown |
Tin | Operaciones Metalurgical S.A. | DRC Conflict-Free |
Tin | PT Alam Lestari Kencana | Unknown |
Tin | PT Aries Kencana Sejahtera | Unknown |
Tin | PT Artha Cipta Langgeng | Unknown |
Tin | PT ATD Makmur Mandiri Jaya | DRC Conflict-Free |
Tin | PT Babel Inti Perkasa | DRC Conflict-Free |
Tin | PT Bangka Kudai Tin | Unknown |
Tin | PT Bangka Putra Karya | DRC Conflict-Free |
Tin | PT Bangka Timah Utama Sejahtera | Unknown |
Tin | PT Bangka Tin Industry | DRC Conflict-Free |
Tin | PT Belitung Industri Sejahtera | DRC Conflict-Free |
Tin | PT BilliTin Makmur Lestari | Unknown |
Tin | PT Bukit Timah | DRC Conflict-Free |
Tin | PT DS Jaya Abadi | DRC Conflict-Free |
Tin | PT Eunindo Usaha Mandiri | DRC Conflict-Free |
Tin | PT Fang Di MulTindo | Unknown |
Tin | PT Inti Stania Prima | Unknown |
Tin | PT JusTindo | Unknown |
Tin | PT Karimun Mining | Unknown |
Tin | PT Mitra Stania Prima | DRC Conflict-Free |
Tin | PT Panca Mega Persada | DRC Conflict-Free |
Tin | PT Pelat Timah Nusantara Tbk | Unknown |
Tin | PT Prima Timah Utama | DRC Conflict-Free |
Tin | PT REFINED BANGKA TIN | DRC Conflict-Free |
Tin | PT Sariwiguna Binasentosa | DRC Conflict-Free |
Tin | PT Seirama Tin investment | Unknown |
Tin | PT Stanindo Inti Perkasa | DRC Conflict-Free |
Tin | PT Sumber Jaya Indah | Unknown |
Tin | PT Supra Sukses Trinusa | Unknown |
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Tin | PT Timah (Persero) Tbk Kundur | DRC Conflict-Free |
Tin | PT Timah (Persero) Tbk Mentok | DRC Conflict-Free |
Tin | PT Tinindo Inter Nusa | DRC Conflict-Free |
Tin | Rui Da Hung | Unknown |
Tin | Soft Metais, Ltda. | Unknown |
Tin | Thaisarco | DRC Conflict-Free |
Tin | VQB Mineral and Trading Group JSC | Unknown |
Tin | White Solder Metalurgia e Mineração Ltda. | DRC Conflict-Free |
Tin | Yunnan Chengfeng Non-ferrous Metals Co.,Ltd. | Unknown |
Tin | Yunnan Tin Group (Holding) Company Limited | DRC Conflict-Free |
Tungsten | A.L.M.T. TUNGSTEN Corp. | Unknown |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | Unknown |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | Unknown |
Tungsten | Dayu Weiliang Tungsten Co., Ltd. | Unknown |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | Unknown |
Tungsten | Ganxian Shirui New Material Co., Ltd. | Unknown |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | DRC Conflict-Free |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | DRC Conflict-Free |
Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | Unknown |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | DRC Conflict-Free |
Tungsten | Global Tungsten & Powders Corp. | DRC Conflict-Free |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | Unknown |
Tungsten | H.C. Starck GmbH | Unknown |
Tungsten | H.C. Starck Smelting GmbH & Co.KG | Unknown |
Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | Unknown |
Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | DRC Conflict-Free |
Tungsten | Japan New Metals Co., Ltd. | DRC Conflict-Free |
Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | Unknown |
Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | DRC Conflict-Free |
Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | Unknown |
Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | Unknown |
Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | Unknown |
Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | Unknown |
Tungsten | Kennametal Fallon | Unknown |
Tungsten | Kennametal Huntsville | Unknown |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | DRC Conflict-Free |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | Unknown |
Tungsten | Pobedit, JSC | Unknown |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Unknown |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd | DRC Conflict-Free |
Tungsten | Wolfram Bergbau und Hütten AG | Unknown |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | DRC Conflict-Free |
Tungsten | Xiamen Tungsten Co., Ltd. | DRC Conflict-Free |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | Unknown |
**Based on CFSI’s Conflict-free Smelter Program results through March 31, 2015.
Countries of Origin of Conflict Minerals
The countries of origin of the Conflict Minerals processed by the facilities listed in Table 1 are believed to include countries listed in Table 2.
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Table 2: Countries of Origin |
Angola |
Argentina |
Australia |
Austria |
Belgium |
Bolivia |
Brazil |
Burundi |
Canada |
Central African Republic |
Chile |
China |
Colombia |
Cote D’Ivoire |
Czech Republic |
Djibouti |
Egypt |
Estonia |
Ethiopia |
France |
Germany |
Guyana |
Hungary |
India |
Indonesia |
Ireland |
Israel |
Japan |
Kazakhstan |
Kenya |
Laos |
Madagascar |
Malaysia |
Mexico |
Mongolia |
Mozambique |
Myanmar |
Namibia |
Netherlands |
Nigeria |
Papua New Guinea |
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Peru |
Philippines |
Portugal |
Republic of Congo |
Russia |
Rwanda |
Sierra Leone |
Singapore |
Slovakia |
South Africa |
South Korea |
South Sudan |
Spain |
Suriname |
Sweden |
Switzerland |
Taiwan |
Tanzania |
Thailand |
The Democratic Republic of Congo |
Turkey |
Uganda |
United Kingdom |
United States of America |
Uzbekistan |
Vietnam |
Zambia |
Zimbabwe |
Efforts to determine the Conflict Minerals’ Mine or Location of Origin
BlackBerry’s efforts to determine the conflict minerals’ mine or location of origin included two approaches: (i) use of the CMRT as a method to query and transmit sourcing information along the supply chain; and (ii) reliance on, and support for, the CFSP as an independent third party audit solution through which mineral sources are identified and independently evaluated.
The CMRT helps a company to identify the smelters and refiners within its supply chain and their sources of minerals. The use of the CMRT by industry participants is relatively new and is dependent upon each tier in the supply chain collecting information from their direct suppliers and passing it on to customers. The amount of detail being collected by this process is improving quickly; however, considering the number of tiers within BlackBerry’s supply chain, we expect that several reporting cycles will be needed to complete the data collection.
Mineral sources are valuable intellectual property for most smelters, and the OECD Guidance acknowledges that reporting of information may be limited by concerns of business confidentiality. An independent third party audit solution such as the CFSP can offer an efficient means to address these confidentiality concerns and to help promote the reliability of information collected. BlackBerry has therefore incorporated reliance on the CFSP as an element of its due diligence process. Through the course of the CFSP smelter validation process, independent auditors review information on the mines of origin for the smelters and refiners. To be compliant with the CFSP, smelters and refiners must have disclosed the identities of their mines or locations of origin to the auditors, and the auditors must have independently validated that sufficient evidence exists to support the sourcing claims and that those sources are DRC conflict-free.
BlackBerry is a member of the CFSI and is very active in supporting the implementation and expansion of the program on multiple fronts.
Steps to Improve Due Diligence
BlackBerry is committed to being a socially and environmentally responsible corporation, within our own activities and through those in our supply chain. We recognize that the maturity of the industry in its implementation of responsible minerals sourcing activities is still developing and that progress can be best made through a collaboration of stakeholders.
BlackBerry expects to continue to engage with relevant first-tier suppliers to improve the due diligence processes exercised regarding the source and chain of custody of the conflict minerals used in the parts and components they supply to us. We intend to further impress upon them our expectation that they apply the OECD Guidance in good faith.
We also expect to continue to focus our efforts on working with industry peers through the CFSI to improve the systems of transparency and control and leverage those systems within our own supply chain.
Although circumstances may change necessitating an adjustment of plans, specific steps we are considering taking to improve our due diligence in 2015 include:
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1) | Providing additional guidance for relevant first-tier suppliers on conflict mineral reporting and the OECD Guidance; |
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2) | Further enhancing our messaging regarding the use of CFSP, or equivalent, validated smelters and refiners; |
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3) | Using the updated CMRT and latest smelter lists for collecting due diligence information from our suppliers; |
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4) | Implementing an improved communication and data management process to increase transparency, clarity, and efficiency; and |
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5) | Continuing our active participation in the CFSI, including the verification and engagement of smelters in the CFSP. |
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