UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
LOGITECH INTERNATIONAL S.A.
(Exact name of the registrant as specified in its charter)
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| Canton of Vaud, Switzerland | | 0-29174 | None |
(State or other jurisdiction of incorporation or organization) | | (Commission File Number) | (IRS Employer Identification No.) |
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Logitech International S.A. EPFL - Quartier de l'Innovation Daniel Borel Innovation Center 1015 Lausanne, Switzerland c/o Logitech Inc. 3930 North First Street, San Jose, California | 95134 |
| (Address of principal executive offices) | (Zip code) |
Samantha Harnett, Chief Legal Officer (510) 713-4520
(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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| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
| Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended |
Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
A copy of Logitech’s Conflict Minerals Report filed for the reporting period January 1, 2023 to December 31, 2023 is provided as Exhibit 1.01 hereto and is publicly available on Logitech’s website at https://ir.logitech.com/financial-info/sec-filings/. Logitech has adopted a Responsible Sourcing of Minerals Policy which can be found at https://www.logitech.com/content/dam/logitech/en/sustainability/pdf/resources/responsible-sourcing-minerals-policy-sept-2023.pdf.
The content on, or accessible through, any website referred to in this Form SD or the attached Conflict Minerals Report is included for general information only and is not incorporated by reference in this Form SD or the attached Conflict Minerals Report.
Item 1.02 Exhibit
Pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 (“Rule 13p-1”), Logitech has filed this Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report as Exhibit 1.01 hereto.
Section 2 – Resource Extraction Issuer Disclosure
Item 2.01 Resource Extraction Issuer Disclosure and Report
Not applicable.
Section 3 – Exhibits
Item 3.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
SIGNATURE
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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| LOGITECH INTERNATIONAL S.A. | | |
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| /s/ JOHANNA (HANNEKE) FABER | | May 23, 2024 |
| Johanna (Hanneke) Faber | | |
| Chief Executive Officer | | |
Exhibit 1.01
LOGITECH INTERNATIONAL S.A.
CONFLICT MINERALS REPORT
FOR THE REPORTING PERIOD FROM JANUARY 1 TO DECEMBER 31, 2023
SECTION ONE: INTRODUCTION
This report for the calendar year ended December 31, 2023 is prepared in accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). In this Conflict Minerals Report (“CMR”), references to “Logitech,” the “Company,” “we,” “us” or “our” refer to Logitech International S.A. and its majority-owned subsidiaries.
The Rule imposes certain obligations on Securities and Exchange Commission (“SEC”) registrants whose products contain conflict minerals that are necessary to the functionality or production of their products (referred to as “conflict minerals”). Logitech manufactures or contracts to manufacture products that may contain tantalum, tin, tungsten, and gold (“3TG”) that are necessary to the functionality or production of the products. Accordingly, the Company has undertaken the measures described in this CMR to trace the origin of these minerals and whether they may have been sourced from the Covered Countries. The Covered Countries for purposes of the Rule are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Statements in this CMR are based on our due diligence activities performed to date in good faith and are based on information available as of March 29, 2024, unless otherwise indicated. Factors that could affect the accuracy of these statements include, but are not limited to, implementation of compliance measures by our direct and indirect suppliers, incomplete supplier data, availability of smelter and refiner (collectively referred to as “Smelters” in this CMR) data, errors or omissions by suppliers or Smelters, ongoing certification of Smelters, continued guidance or amendments to the Rule, and other factors. Additionally, this CMR contains forward-looking statements reflecting the efforts we strive to achieve in the future as we continue to improve our responsible sourcing program. These forward-looking statements are based on current expectations and assumptions that are subject to risks and uncertainties. For more information, see Forward-Looking Statements below.
Company Overview
Founded in 1981, and headquartered in Lausanne, Switzerland, Logitech International (“Logitech” or the “Company”) is a Swiss public company listed on the SIX Swiss Exchange (LOGN) and on the Nasdaq Global Select Market (LOGI). Logitech’s website address is www.logitech.com.
Logitech designs software-enabled hardware solutions that help businesses thrive and bring people together when working, creating, gaming and streaming. As a point of connection between people and the digital world, our mission is to extend human potential in work and play, in a way that is good for people and the planet. We sell these products through a number of brands, including Logitech, Logitech G and others.
Our diverse portfolio includes: Gaming, Keyboards & Combos, Pointing Devices, Video Collaboration, Webcams, Tablet Accessories, and Headsets.
SECTION TWO: DESCRIPTION OF PRODUCTS COVERED BY THIS REPORT
Conflict minerals in the form of the 3TG were necessary to the functionality or production of the following categories of products that we manufactured or contracted to have manufactured for us during 2023:
●Gaming: Gaming mice, racing wheels, headsets, keyboards, and microphones
●Keyboards & Combos: Corded and cordless keyboards and combos (keyboard-and-mouse combinations)
●Pointing Devices: Mice
●Video Collaboration (VC): Conference room cameras
●Webcams: PC-based webcams that including streaming cameras and VC webcams
●Tablet Accessories: Keyboards for tablets and digital pen for iPad
●Headsets: PC and VC headsets, in-ear headphones, and premium wireless earbuds
●Other: mobile speakers and PC speakers
These products are more fully described in our Annual Report on Form 10-K for the fiscal year ended March 31, 2024, which can be accessed on our website at: https://ir.logitech.com/financial-info/sec-filings/ or on the SEC’s website at http://www.sec.gov.
SECTION THREE: REASONABLE COUNTRY OF ORIGIN INQUIRY
For the reporting period from January 1 to December 31, 2023 (“Reporting Period”), Logitech conducted a reasonable country of origin inquiry (“RCOI”) to determine whether any of the conflict minerals necessary to the functionality or production of the products (“Necessary Conflict Minerals”) that we manufactured or contracted to manufacture originated in the Covered Countries. To make this determination, we engaged with our direct suppliers of materials, parts, components or products potentially containing 3TG (“In-Scope Suppliers”) to identify the Smelters of the Necessary Conflict Minerals.
Our RCOI included the following steps:
●From a total of 460 suppliers, 255 out of 460 were identified as In-Scope Suppliers who may contribute Necessary Conflict Minerals to our products. During the Reporting Period, we continued to refine the list of In-Scope Suppliers and removed those which did not use 3TG or were no longer in Logitech’s supply chain.
●We surveyed our In-Scope Suppliers using the current version of the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template Revision 6.31 (“CMRT” or “Template”), which includes questions about the location or mine of origin. In-Scope Suppliers are obligated to make similar efforts to survey their supply chain using CMRT and report the facilities and location or mine of origin for 3TG. Given our position in the supply chain and the fact that Logitech does not directly purchase raw materials, we are several tiers away from the Smelters and country of origin for the 3TG used in our products. We therefore rely on our first-tier suppliers to provide information and we carry out due diligence activities to check and verify the accuracy of information provided by those suppliers.
●We reviewed the information provided by the In-Scope Suppliers with respect to a number of evaluation criteria to assess the adequacy of the information provided and determine the potential for sourcing from the Covered Countries. The reviewing criteria included but was not limited to:
○Mandatory fields of the CMRT report were complete and accurate;
○No contradictory information in the CMRT report;
○The Smelters information was consistent with the Smelter database available to RMI members; and
○Verification of supplier 3TG reported usage against Bill of Materials by applying established criteria and knowledge of where 3TG materials are utilized at component/part and product levels.
●We followed up with In-Scope Suppliers where necessary to clarify the information they provided or to seek additional information as part of our due diligence efforts.
●We implemented regular review and consolidation of all supplier responses. If any supplier did not provide timely and accurate information, an escalation process was engaged to address non-responders and obtain required information.
●We documented country of origin information of facilities which were identified by In-Scope Suppliers from multiple resources, including the independent third-party audit programs (e.g., RMI RCOI data), and an independent third-party assessment.
Our RCOI executive outcomes:
We sought and obtained a 100% response rate from In-Scope Suppliers. In-Scope Suppliers’ responses and RMI RCOI data indicated that some of the Smelters used in our supply chain may obtain 3TG from the Covered Countries. Other In-Scope Suppliers are using 3TG sources from outside the Covered Countries, recycled or scrap 3TG. Accordingly, we conducted due diligence to determine the source of 3TG metals and have prepared this Conflict Minerals Report.
Table 1. RCOI response of Logitech
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| In-Scope Suppliers # | 255 |
| Response Ratio | 100% |
SECTION FOUR: DUE DILIGENCE MEASURES
We conducted due diligence on the source and chain of custody of the 3TG that are necessary to the functionality or production of our products to ascertain whether these conflict minerals originated in the Covered Countries and directly or indirectly financed or benefited armed groups (as such term is defined by the SEC in Form SD) in any of these countries.
Design of Our Due Diligence Measures
Our conflict minerals due diligence measures are aligned with the requirements of the Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Third Edition (the “OECD Guidance”), as applicable for tin, tantalum, tungsten, gold and downstream companies (as the term is defined in the OECD Guidance), in all material respects. We designed our due diligence measures 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 by participating in industry organizations; and
5.Report on our conflict minerals supply chain due diligence activities annually.
Due Diligence Measures Performed
As a purchaser, Logitech is many tiers removed from the mining of 3TG; Logitech does not purchase raw ore or unrefined conflict minerals, and does not directly purchase from the Covered Countries. The Smelters are consolidating points for raw ore and are best-positioned to determine and know the origin of the ores. For downstream users like Logitech, it is not possible to determine the origin of 3TG without information from suppliers and Smelters.
We are a member of the Responsible Minerals Initiative (“RMI”), an initiative of the Responsible Business Alliance. As a member of the RMI, we leverage the due diligence conducted on Smelters by the RMI’s Responsible Minerals Assurance Process (the “RMAP”). The RMAP uses independent private sector auditors to audit Smelters who agree to participate, including their 3TG chain of custody and the mines of origin. Smelters are deemed to be conformant with RMAP when the independent auditor has taken a risk-based approach to validate Smelters’ company level management processes for responsible mineral procurement. RMAP Assessments are valid for a period of either one or three years, depending on a number of factors.
Our due diligence measures included the following activities:
1.We utilized our existing experienced internal team to implement Logitech’s Responsible Sourcing of Minerals Program again in 2023. The team includes representatives from the following functions: Sustainability, Global Sourcing, Legal, Investor Relations, and Finance.
2.We reviewed and updated our Responsible Sourcing of Minerals Policy in 2023 and continue to make it available at: https://www.logitech.com/content/dam/logitech/en/sustainability/pdf/resources/responsible-sourcing-minerals-policy-sept-2023.pdf
3.We established requirements and continued to incorporate these requirements into our standard supplier contracts to define Logitech’s expectations of suppliers regarding sourcing of conflict minerals and reporting of information to Logitech. In addition, the Sustainability team and the Sourcing team quarterly review the new suppliers in order to ensure that they are enrolled in the Logitech’s Responsible Sourcing of Minerals Program.
4.We compared the Smelters identified by relevant In-Scope Suppliers through the supply chain survey against the list of facilities that are conformant to a responsible mineral sourcing validation program or undergoing an assessment such as the RMAP Conformant Smelters & Refiners list, the London Bullion Market Association (the “LBMA”) Good Delivery List, and the Responsible Jewellery Council (the “RJC”) Chain-of-Custody Certification Program.
5.We defined a risk management plan for the relevant In-Scope Suppliers that present a potential conflict minerals risk. In the Reporting Period, we continued to engage with a number of In-Scope Suppliers, e.g. training through video conference and phone. In addition, we requested those In-Scope Suppliers, who reported Smelters not yet participating in an independent third-party audit program, to provide a smelter action plan (SAP) to reach 100% participation by either removing those Smelters from their supply chain or encouraging Smelters to participate in independent third-party audit programs. We also monitored their SAP progress monthly.
6.As of March-22, 2024, we removed 18 Smelters from our supply chain that were not conforming to the Logitech Responsible Sourcing of Minerals Policy or were erroneously or unintentionally reported in 2023 by In-Scope Suppliers but were actually not in our supply chain.
7.We supported the RMI Responsible Minerals Assurance Process, and required relevant In-Scope Suppliers in the Logitech supply chain to encourage the facilities in their supply chain to participate in the RMAP. As a RMI member, we also support the refinement and expansion of the RMAP Conformant Smelters & Refiners list of participating Smelters through its membership in the RMI, as well as the smelter engagement efforts in the RMI working group.
8.We take a proactive approach by directly engaging with certain Smelters that may be at risk of non-conformance to ensure their consistent participation in the RMAP program.
9.To the extent reasonably possible, we also verified the mine sources information reported by In-Scope Suppliers relying on different resources, e.g., contacting Smelters directly, reviewing publicly available information, and utilizing RMI resources. We also utilized an independent third party to provide an assessment of Smelters disclosed by our In-Scope Suppliers, to conduct Smelter RCOI, verify data and identify risks in Smelters that have not yet undergone the RMAP or that have lost their RMAP conformant status.
SECTION FIVE: DUE DILIGENCE RESULTS
Smelters Due Diligence Results
Our supplier survey data revealed a total of 261 Smelters as potential sources of 3TG in the supply chain. Of these 261 potential Smelters, 18 Smelters were removed from our supply chain (see above), and nine Smelters were not in active operation. Accordingly, 234 operational Smelter facilities were identified as potential sources of 3TG in our supply chain.
Further verifying the certified status of the 234 Smelters, 230 of these entities were conformant to a responsible mineral sourcing validation program (i.e. the RMAP Conformant Smelters & Refiners list, the LBMA Good Delivery List, or the RJC Chain-of-Custody Certification Program). According to the RMAP Active Smelters & Refiners list, another four Smelters are undergoing the RMAP assessment (referred to as “Active” in the table below). Therefore, the total number of smelters identified as “conformant” or “active” amounts to 234 (100%).
Table 2 below illustrates our progress with Smelters status compared to reporting year 2022.
Table 2: Progress in Smelters’ Status
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| 2022 | 2023 |
| Number | % of Total | Number | % of Total |
| Smelters listed as “Conformant” by 3rd party audit program | 232 | 96.3% | 230 | 98.3% |
| Smelters listed as “Active” by 3rd party audit program | 2 | 0.8% | 4 | 1.7% |
| Smelters confirmed by an independent 3rd party assessment to not be sourcing from the Covered Countries | 7 | 2.9% | 0* | N/A |
| Total | 241 | 100% | 234 | 100% |
* For the Reporting Period, there were no Smelters enrolled in the RCOI inquiry that needed confirmation by an independent 3rd party assessment to not be sourcing from the Covered Countries, since these Smelters were ultimately either Conformant to, or Active in, a third-party audit program, or removed from our supply chain.
Table 3 further illustrates our results for each 3TG metal by setting forth the number and percentage of Smelters’ facilities that were either participating in a third-party validation program or confirmed by an independent third party to not be sourcing from the Covered Countries as of March 22, 2024.
Table 3: 2023 Smelters Participating in Third-Party Audit Programs or confirmed by an independent Third Party to not be sourcing from the Covered Countries, by Metal
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| Metal | Smelters participating in third-party audit programs |
| Tantalum | 34 of 34 (100%) |
| Tin | 68 of 68 (100%) |
| Tungsten | 32 of 32 (100%) |
| Gold | 100 of 100 (100%) |
As result of our due diligence activities summarized above, we determined the following as of March 22, 2024:
●All 234 Smelters identified by our In-Scope Suppliers are either conformant to a third-party responsible minerals sourcing audit program, or have begun participating in such a program for the Reporting Period.
●We have no reason to believe that any of the 234 Smelters directly or indirectly finance or benefit armed groups in the Covered Countries.
Appendix A provides the complete list of 234 Smelters identified in Logitech’s supply chain which processed 3TG during the Reporting Period. Appendix A lists each Smelter by metal, smelter name, and location country. Based on the information provided by Logitech’s suppliers, Smelters, as well as from third-party audit programs, Logitech believes that the 3TG contained in its products originated from the countries listed in Appendix B, as well as from recycled and scrap sources.
Efforts to Determine the Conflict Minerals’ Mine or Location of Origin
Through our participation in RMI, the OECD implementation programs, and requesting our suppliers to complete the CMRT, we have determined that seeking information about 3TG Smelters in our supply chain represents the most reasonable effort we can make to determine the mine or location of origin of the 3TG in our supply chain, as outlined in Section Four above (“Due Diligence Measures”).
SECTION SIX: STEPS TO BE TAKEN TO MITIGATE RISK
Logitech currently intends to undertake the following steps, during the next compliance period, with the intention of further mitigating risks associated with supply chain sourcing and conflict minerals:
●Require that 3TG sourcing Smelters remain at 100% participating in the third-party audit programs.
○Retain the same approach in existing suppliers through due diligence management
○Request action from our direct suppliers to have the Smelters that were removed from the RMAP Conformant list to either re-apply and re-obtain their “Conformant” status or remove them from the supply chain; and
○Early engagement with new suppliers to address 3TG sourcing with a consistent approach
●Continue our training, auditing, engagement and other due diligence activities with suppliers to:
○Require all In-Scope Suppliers understand and fully comply with our established Responsible Sourcing of Minerals Policy and associated requirements;
○Maintain oversight of our supply chain and identify the source of any 3TG;
○Strengthen internal partnerships to identify raw material risk at an early product development stage;
○Confirm the status of identified Smelters through independent Responsible Minerals Smelter validation programs; and
○Encourage Smelters to participate in third-party audit programs such as the RMI Responsible Minerals Assurance Process or equivalent programs.
●Continue our support of RMI to encourage further adoption and improvement of relevant good practices, programs, tools and standards.
●Develop due diligence plans showing the actions the supplier will take to engage, request and encourage Smelters that are not yet engaged in RMAP or an equivalent certification program, and also raise awareness of the Smelters about the risk of non-conformance and take proactive action to address deficiencies and to obtain evidence of compliant responsible minerals status.
Forward-Looking Statements
This Conflict Minerals Report contains forward-looking statements within the meaning of the federal securities laws including statements related to our business, products and conflict minerals efforts, design of our due diligence measures and related goals, our list of sourcing countries, and steps we intend to take in the future to mitigate the risk that the conflict minerals used in our products directly or indirectly finance or benefit armed groups in the Covered Countries. You can identify forward-looking statements by the fact that they do not relate strictly to historical or current facts. Forward-looking statements also include, among others, those statements including the words "anticipate," "believe," "could," "estimate," "expect," "forecast," "intend," "may," "plan," "project," "predict," "should," "will" and similar language. These statements reflect our views and assumptions as of the date of this Report. All forward-looking statements involve risks and uncertainties that could cause our actual performance to differ materially from those anticipated in the forward-looking statements depending on a variety of factors, including implementation of compliance measures by our direct and indirect suppliers, incomplete supplier data, availability of Smelter data, errors or omissions by suppliers or Smelters, ongoing certification of Smelters, failure to carry out our plans in a timely manner or at all; lack of cooperation by our suppliers, their respective suppliers and smelters; uncertainties introduced to our supply chain by acquisitions; internal and external resource constraints; political developments in the Covered Countries and regulatory developments in the United States, as well as those risks and uncertainties disclosed under the sections entitled “Risk Factors” and “Management’s Discussion and Analysis of Financial Condition and Results of Operations” in our Annual Report on Form 10-K for the fiscal year ended March 31, 2024. You are cautioned not to place undue reliance on the forward-looking statements, which speak only as of the date of this Report. We undertake no obligation to publicly release any revisions to the forward-looking statements or reflect events or circumstances after the date of this document.
Appendix A
Identified Smelters in Logitech’s Supply Chain for Reporting Year 2023
This list presents consolidated information compiled from the CMRT forms provided by our In-Scope Suppliers, and the Smelter names and location as reported by the RMI as of March 22, 2024.
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| Metal | Smelter Name | Smelter Location Country |
| Tantalum | AMG Brasil | Brazil |
| Tantalum | D Block Metals, LLC | United States of America |
| Tantalum | F&X Electro-Materials Ltd. | China |
| Tantalum | FIR Metals & Resource Ltd. | China |
| Tantalum | Global Advanced Metals Aizu | Japan |
| Tantalum | Global Advanced Metals Boyertown | United States of America |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | China |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | China |
| Tantalum | Jiangxi Tuohong New Raw Material | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | China |
| Tantalum | Jiujiang Tanbre Co., Ltd. | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | China |
| Tantalum | KEMET de Mexico | Mexico |
| Tantalum | Materion Newton Inc. | United States of America |
| Tantalum | Metallurgical Products India Pvt., Ltd. | India |
| Tantalum | Mineracao Taboca S.A. | Brazil |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | China |
| Tantalum | NPM Silmet AS | Estonia |
| Tantalum | PowerX Ltd. | Rwanda |
| Tantalum | QuantumClean | United States of America |
| Tantalum | Resind Industria e Comercio Ltda. | Brazil |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | China |
| Tantalum | Taki Chemical Co., Ltd. | Japan |
| Tantalum | TANIOBIS Co., Ltd. | Thailand |
| Tantalum | TANIOBIS GmbH | Germany |
| Tantalum | TANIOBIS Japan Co., Ltd. | Japan |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | Germany |
| Tantalum | Telex Metals | United States of America |
| Tantalum | Ulba Metallurgical Plant JSC | Kazakhstan |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | China |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | China |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | China |
| Tin | Alpha | United States of America |
| Tin | Aurubis Beerse | Belgium |
| Tin | Aurubis Berango | Spain |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | China |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | China |
| Tin | China Tin Group Co., Ltd. | China |
| | | | | | | | |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | Brazil |
| Tin | CRM Synergies | Spain |
| Tin | CV Ayi Jaya | Indonesia |
| Tin | CV Venus Inti Perkasa | Indonesia |
| Tin | Dowa | Japan |
| Tin | DS Myanmar | Myanmar |
| Tin | EM Vinto | Bolivia (Plurinational State of) |
| Tin | Estanho de Rondonia S.A. | Brazil |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | Brazil |
| Tin | Fenix Metals | Poland |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | China |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | China |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | China |
| Tin | Jiangxi New Nanshan Technology Ltd. | China |
| Tin | Luna Smelter, Ltd. | Rwanda |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | Brazil |
| Tin | Malaysia Smelting Corporation (MSC) | Malaysia |
| Tin | Metallic Resources, Inc. | United States of America |
| Tin | Mineracao Taboca S.A. | Brazil |
| Tin | Mining Minerals Resources SARL | Democratic Republic of the Congo |
| Tin | Minsur | Peru |
| Tin | Mitsubishi Materials Corporation | Japan |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | Thailand |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | Operaciones Metalurgicas S.A. | Bolivia (Plurinational State of) |
| Tin | Precious Minerals and Smelting Limited | India |
| 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 Babel Surya Alam Lestari | Indonesia |
| Tin | PT Bangka Prima Tin | Indonesia |
| Tin | PT Bangka Serumpun | Indonesia |
| Tin | PT Belitung Industri Sejahtera | Indonesia |
| Tin | PT Bukit Timah | Indonesia |
| Tin | PT Cipta Persada Mulia | Indonesia |
| Tin | PT Menara Cipta Mulia | Indonesia |
| Tin | PT Mitra Stania Prima | Indonesia |
| Tin | PT Mitra Sukses Globalindo | Indonesia |
| Tin | PT Premium Tin Indonesia | Indonesia |
| Tin | PT Prima Timah Utama | Indonesia |
| Tin | PT Putera Sarana Shakti (PT PSS) | Indonesia |
| Tin | PT Rajawali Rimba Perkasa | Indonesia |
| Tin | PT Rajehan Ariq | Indonesia |
| Tin | PT REFINED BANGKA TIN | Indonesia |
| Tin | PT Sariwiguna Binasentosa | Indonesia |
| Tin | PT Stanindo Inti Perkasa | Indonesia |
| | | | | | | | |
| Tin | PT Sukses Inti Makmur | Indonesia |
| Tin | PT Timah Nusantara | Indonesia |
| Tin | PT Timah Tbk Kundur | Indonesia |
| Tin | PT Timah Tbk Mentok | Indonesia |
| Tin | PT Tinindo Inter Nusa | Indonesia |
| Tin | PT Tommy Utama | Indonesia |
| Tin | Resind Industria e Comercio Ltda. | Brazil |
| Tin | Rui Da Hung | Taiwan, Province of China |
| Tin | Super Ligas | Brazil |
| Tin | Thaisarco | Thailand |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | China |
| Tin | Tin Technology & Refining | United States of America |
| Tin | White Solder Metalurgia e Mineracao Ltda. | Brazil |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | China |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | China |
| Tungsten | A.L.M.T. Corp. | Japan |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | Vietnam |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | China |
| Tungsten | Cronimet Brasil Ltda | Brazil |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders Corp. | United States of America |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | China |
| Tungsten | H.C. Starck Tungsten GmbH | Germany |
| Tungsten | Hubei Green Tungsten Co., Ltd. | China |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | China |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | China |
| Tungsten | Japan New Metals Co., Ltd. | Japan |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | China |
| 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 | Jiangxi Yaosheng Tungsten Co., Ltd. | China |
| Tungsten | Kennametal Fallon | United States of America |
| Tungsten | Kennametal Huntsville | United States of America |
| Tungsten | Lianyou Metals Co., Ltd. | Taiwan, Province of China |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | China |
| Tungsten | Masan High-Tech Materials | Vietnam |
| Tungsten | Niagara Refining LLC | United States of America |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | Philippines |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | Germany |
| Tungsten | Tungsten Vietnam Joint Stock Company | Vietnam |
| Tungsten | Wolfram Bergbau und Hutten AG | Austria |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | China |
| Tungsten | Xiamen Tungsten Co., Ltd. | China |
| | | | | | | | |
| Gold | 8853 S.p.A. | Italy |
| Gold | Abington Reldan Metals, LLC | United States of America |
| Gold | Advanced Chemical Company | United States of America |
| Gold | Agosi AG | Germany |
| Gold | Aida Chemical Industries Co., Ltd. | Japan |
| Gold | Al Etihad Gold Refinery DMCC | United Arab Emirates |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | Uzbekistan |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | Brazil |
| Gold | Argor-Heraeus S.A. | Switzerland |
| Gold | Asahi Pretec Corp. | Japan |
| Gold | Asahi Refining Canada Ltd. | Canada |
| Gold | Asahi Refining USA Inc. | United States of America |
| Gold | Asaka Riken Co., Ltd. | Japan |
| Gold | Aurubis AG | Germany |
| Gold | Bangalore Refinery | India |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | Philippines |
| Gold | Boliden AB | Sweden |
| Gold | C. Hafner GmbH + Co. KG | Germany |
| Gold | CCR Refinery - Glencore Canada Corporation | Canada |
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | Chimet S.p.A. | Italy |
| Gold | Chugai Mining | Japan |
| Gold | Coimpa Industrial LTDA | Brazil |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Dowa | Japan |
| Gold | DSC (Do Sung Corporation) | Korea, Republic of |
| Gold | Eco-System Recycling Co., Ltd. East Plant | Japan |
| Gold | Eco-System Recycling Co., Ltd. North Plant | Japan |
| Gold | Eco-System Recycling Co., Ltd. West Plant | Japan |
| Gold | Gold by Gold Colombia | Colombia |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | China |
| Gold | Heimerle + Meule GmbH | Germany |
| Gold | Heraeus Germany GmbH Co. KG | Germany |
| Gold | Heraeus Metals Hong Kong Ltd. | China |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | China |
| Gold | Ishifuku Metal Industry Co., Ltd. | Japan |
| Gold | Istanbul Gold Refinery | Turkey |
| Gold | Italpreziosi | Italy |
| Gold | Japan Mint | Japan |
| Gold | Jiangxi Copper Co., Ltd. | China |
| Gold | JX Nippon Mining & Metals Co., Ltd. | Japan |
| Gold | Kazzinc | Kazakhstan |
| Gold | Kennecott Utah Copper LLC | United States of America |
| Gold | KGHM Polska Miedz Spolka Akcyjna | Poland |
| Gold | Kojima Chemicals Co., Ltd. | Japan |
| Gold | Korea Zinc Co., Ltd. | Korea, Republic of |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | L'Orfebre S.A. | Andorra |
| | | | | | | | |
| Gold | LS-NIKKO Copper Inc. | Korea, Republic of |
| Gold | LT Metal Ltd. | Korea, Republic of |
| Gold | Materion | United States of America |
| Gold | Matsuda Sangyo Co., Ltd. | Japan |
| Gold | Metal Concentrators SA (Pty) Ltd. | South Africa |
| Gold | Metalor Technologies (Hong Kong) Ltd. | China |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | Singapore |
| Gold | Metalor Technologies (Suzhou) Ltd. | China |
| Gold | Metalor Technologies S.A. | Switzerland |
| Gold | Metalor USA Refining Corporation | United States of America |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | Mexico |
| Gold | Mitsubishi Materials Corporation | Japan |
| Gold | Mitsui Mining and Smelting Co., Ltd. | Japan |
| Gold | MKS PAMP SA | Switzerland |
| Gold | MMTC-PAMP India Pvt., Ltd. | India |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | Turkey |
| Gold | Navoi Mining and Metallurgical Combinat | Uzbekistan |
| Gold | NH Recytech Company | Korea, Republic of |
| Gold | Nihon Material Co., Ltd. | Japan |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | Austria |
| Gold | Ohura Precious Metal Industry Co., Ltd. | Japan |
| Gold | Planta Recuperadora de Metales SpA | Chile |
| Gold | PT Aneka Tambang (Persero) Tbk | Indonesia |
| Gold | PX Precinox S.A. | Switzerland |
| Gold | Rand Refinery (Pty) Ltd. | South Africa |
| Gold | REMONDIS PMR B.V. | Netherlands |
| Gold | Royal Canadian Mint | Canada |
| Gold | SAAMP | France |
| Gold | Safimet S.p.A | Italy |
| Gold | Safina a.s. | Czechia |
| Gold | SEMPSA Joyeria Plateria S.A. | Spain |
| Gold | Shandong gold smelting Co., Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | China |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | China |
| Gold | Solar Applied Materials Technology Corp. | Taiwan, Province of China |
| Gold | Sumitomo Metal Mining Co., Ltd. | Japan |
| Gold | SungEel HiMetal Co., Ltd. | Korea, Republic of |
| Gold | T.C.A S.p.A | Italy |
| Gold | Tanaka Kikinzoku Kogyo K.K. | Japan |
| Gold | Tokuriki Honten Co., Ltd. | Japan |
| Gold | TOO Tau-Ken-Altyn | Kazakhstan |
| Gold | Torecom | Korea, Republic of |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | Belgium |
| Gold | United Precious Metal Refining, Inc. | United States of America |
| Gold | Valcambi S.A. | Switzerland |
| Gold | WEEEREFINING | France |
| Gold | Western Australian Mint (T/a The Perth Mint) | Australia |
| | | | | | | | |
| Gold | WIELAND Edelmetalle GmbH | Germany |
| Gold | Yamakin Co., Ltd. | Japan |
| Gold | Yokohama Metal Co., Ltd. | Japan |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | China |
Appendix B
List of Sourcing Countries
Potential Countries of Origin for Conflict Minerals associated with the Smelters listed in Appendix A.
(Based on RMI Conformant Smelter Source Information data, as of March 29, 2024.)
| | | | | | | | | | | |
| Argentina | Ethiopia | Malaysia | Rwanda* |
| Australia | Fiji | Mali | Saudi Arabia |
| Austria | Finland | Mauritania | Senegal |
| Azerbaijan | France | Mexico | Serbia |
| Benin | French Guiana | Mongolia | Sierra Leone |
| Bolivia (Plurinational State of) | Georgia | Morocco | South Africa |
| Botswana | Ghana | Mozambique | Spain |
| Brazil | Guatemala | Myanmar | Sudan |
| Burkina Faso | Guinea | Namibia | Suriname |
| Burundi* | Guyana | New Zealand | Sweden |
| Cambodia | Honduras | Nicaragua | Tanzania* |
| Canada | Indonesia | Niger | Thailand |
| Chile | Japan | Nigeria | Turkey |
| China | Kazakhstan | Oman | Uganda* |
| Colombia | Kenya | Panama | United Kingdom |
| Democratic Republic of the Congo* | South Korea | Papua New Guinea | United States of America |
| Côte d'Ivoire | Kyrgyzstan | Peru | Uzbekistan |
| Dominican Republic | Laos | Philippines | Vietnam |
| Ecuador | Liberia | Portugal | Zambia* |
| Egypt | Madagascar | Russian Federation** | Zimbabwe |
* Covered Countries.
** The Russian Federation is not a Covered Country for purposes of Rule 13p-1 under the Securities Exchange Act of 1934 following which this Report is prepared. Logitech does not source directly from the Russian Federation and is in compliance with international sanctions related to the Russian Federation.
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