UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM SD
Specialized Disclosure Report
Skyworks Solutions, Inc.
(Exact name of registrant as specified in its charter)
Delaware | 001-05560 | 04-2302115 | ||
(State or other jurisdiction of incorporation) | (Commission File Number) | (I.R.S. Employer Identification No.) | ||
20 Sylvan Road, Woburn, MA | 01801 | |||
(Address of principal executive offices) | (Zip Code) | |||
Robert J. Terry, Senior Vice President, General Counsel and Secretary 949-231-3000 | ||
(Name and telephone number, including area code, of the person to contact with in connection with this report) | ||
Check the appropriate box below to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
þ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2017. |
Section 1 – Conflict Minerals Disclosure
Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit
Skyworks Solutions, Inc. (the “Registrant”), has determined that substantially all of its products contain components likely to contain conflict minerals. The Registrant performed a reasonable country of origin inquiry and concluded that a portion of its necessary conflict minerals may have originated in the Democratic Republic of the Congo or an adjoining country. The Registrant knows or has reason to believe that those necessary conflict minerals may not be from recycled or scrap sources. As such, the Registrant proceeded to exercise due diligence on the source and chain of custody of the conflict minerals.
The Registrant has prepared a Conflict Minerals Report, which is attached as Exhibit 1.01 to this Specialized Disclosure Report on Form SD. This Conflict Minerals Report includes a discussion of the due diligence procedures performed, the Registrant’s determinations regarding the source and chain of custody of its conflict minerals, and the other disclosures required pursuant to Rule 13p-1 and Form SD under the Securities Exchange Act of 1934.
The Registrant has disclosed the information above, along with a copy of its Conflict Minerals Report and related materials, on its website, http://www.skyworksinc.com/SustainabilityReporting.aspx. The information contained on our website is not incorporated by reference in this Specialized Disclosure Report on Form SD.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit No. | Description |
1.01 | |
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 undersigned hereunto duly authorized.
Skyworks Solutions, Inc. | |||
May 31, 2018 | By: | /s/ Robert J. Terry | |
Name: | Robert J. Terry | ||
Title: | Senior Vice President, General Counsel and Secretary | ||
Exhibit 1.01
Skyworks Solutions, Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2017
Background
This report for the year ended December 31, 2017, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Conflict Minerals Rule”). The Conflict Minerals Rule was adopted by the Securities and Exchange Commission (the “SEC”) to implement due diligence and disclosure requirements related to conflict minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”). The Conflict Minerals Rule imposes these due diligence and disclosure requirements on companies that file public reports with the SEC and whose manufactured products contain conflict minerals that are necessary to the functionality or production of the products. Conflict minerals are defined as cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten (“3TG”). These requirements apply to reporting companies whatever the geographic origin of the conflict minerals and whether or not they fund armed conflict.
If a registrant can establish that the conflict minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”), or from recycled and scrap sources, the registrant must submit a Specialized Disclosure Report on Form SD that describes the reasonable country of origin inquiry completed. If a registrant has reason to believe that any of the conflict minerals in the registrant’s supply chain may have originated in the Covered Countries (or if the registrant is unable to determine the country of origin of those conflict minerals) and did not originate from recycled or scrap sources, then the issuer must exercise due diligence on the conflict minerals’ source and chain of custody. The registrant must submit a Conflict Minerals Report (the “CMR”) to the SEC that includes a description of those due diligence measures.
Overview
Skyworks Solutions, Inc. (herein referred to as “Skyworks,” the “Company,” “we,” “us,” or “our”), is empowering the wireless networking revolution. Our highly innovative analog semiconductors are connecting people, places and things, spanning a number of new and previously unimagined applications within the automotive, broadband, cellular infrastructure, connected home, industrial, medical, military, smartphone, tablet and wearable markets. We conducted an analysis of our products, including both products that we manufacture and products that we contract for manufacture, and found that substantially all of these products contain components considered likely to contain 3TG. We have conducted a survey of all of our suppliers whose materials or components contain 3TG and have concluded, based on the supplier responses, that certain of our products contain 3TG that originated, or may have originated, in the Covered Countries and that is not from recycled or scrap sources.
This CMR describes the reasonable country of origin inquiry and due diligence we have performed with respect to the source and chain of custody of our conflict minerals, as well as measures we have adopted in order to mitigate the risk that the conflict minerals in our products could benefit armed groups in the Covered Countries.
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Reasonable Country of Origin Inquiry
The Company has an established process by which its suppliers of 3TG are identified. Following identification, those suppliers are surveyed to provide relevant information on their own Conflict Minerals programs along with disclosure of smelters/refiners within their supply chain. The Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template (“CMRT”) is used for this supplier survey activity. The company’s process includes analysis of supplier provided data, feedback to the suppliers regarding issues or improvements necessary, and identification of materials sourcing locations (countries of origin) using resources available to RMI members.
Design of Due Diligence and Measures Taken (Audited)
1. | Design of the Conflict Minerals Program |
To determine the source and chain of custody of 3TG necessary to the functionality and/or production of our products, we conducted due diligence on our supply chain. Our due diligence measures were developed to ascertain whether the 3TG in our products originated in the Covered Countries and, if so, whether armed groups directly or indirectly benefited as a result of the trade in these minerals. Our due diligence measures have been designed to conform, in all material respects, with the framework in The Organization for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (“OECD Guidance”) and the related Supplements for gold and for tin, tantalum and tungsten. Our due diligence process has been designed to comply with the following five steps of the OECD Guidance:
1. | Establishment of strong company management systems; |
2. | Identification and assessment of risks in our supply chain; |
3. | Implementation of a strategy to respond to identified risks; |
4. | Audit of supply chain due diligence; and |
5. | Reporting on supply chain due diligence. |
2. | Due Diligence Measures Taken in 2017 Reporting Period |
Following receipt of supplier-provided CMRTs, the Company evaluated the CMRTs for completeness. Smelters/refiners disclosed in the CMRTs are evaluated against the RMI’s Conflict-Free Smelter lists to determine if the reported smelters/refiners were considered RMI “conformant” or “active” (meaning they are on the RMI Active list and are currently engaged in the process of having an audit scheduled and performed). The Company followed an established process to follow up with suppliers who had not submitted a CMRT deemed valid and acceptable, and also suppliers who reported smelters/refiners within their supply chain that were not on the RMI Conformant or Active lists.
3. Independent Private Sector Audit
We obtained an independent private sector audit of the foregoing by KPMG LLP, which is set forth as Annex C to this CMR.
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Description of Due Diligence (Unaudited)
1. Establishment of Strong Company Management Systems
Conflict Minerals Policy and Work Instruction
We have adopted a conflict minerals policy that makes the Company’s position on this issue clear to all stakeholders. The policy, which is published on our external website along with other Conflict Minerals information at http://www.skyworksinc.com/SustainabilityReporting.aspx, is regularly reviewed and updated as necessary. Pursuant to our conflict minerals policy, we have developed and implemented a documented work instruction, controlled within our established document control system, that governs all due diligence activities and other work processes related to conflict minerals. We also maintain an online grievance reporting system that allows employees, suppliers, and other stakeholders to report anonymously any issues pertaining to the use of conflict minerals in our products.
Internal Management Team
We have established an internal management team for conflict minerals that includes subject matter experts from each of the following groups within Skyworks: Global Risk Management, Global Sourcing (Supply Chain), Legal, Operations, and Corporate Internal Audit. The team of subject matter experts is responsible for implementing our conflict minerals compliance strategy and is led by our Director, Global Risk Management. Senior management is briefed about the results of our due diligence efforts on a regular basis.
Conflict-Free Smelter Program
As we do not typically have a direct relationship with 3TG smelters and refiners, we are engaged and actively cooperate with other major manufacturers in the semiconductor sector and other sectors. As a member of the Responsible Business Alliance (“RBA”), Skyworks is a participating member of the RMI, which is an initiative of the RBA and the Global eSustainability Initiative and which audits smelters’ and refiners’ due diligence activities. The data on which we relied for certain statements in this report was obtained through our membership in the RMI, including but not limited to the “Conformant Smelter Sourcing Information” report for member “SWKS.” The RMI has created the Responsible Minerals Assurance Process (“RMAP”) which provides our industry with valuable due diligence information. Under the RMAP, smelters and refiners voluntarily undergo independent third-party audits of their procurement activities and operations. Through this RMAP audit process, a smelter/refiner is certified as “RMAP-Conformant” if the smelter/refiner has demonstrated that all processed materials originated from conflict-free sources. “Conformant” and “Active” smelter/refiner lists are available on the RMI website and are kept up to date by the RMI.
2. Identification and Assessment of Risks in our Supply Chain
Identification of Potential 3TG Materials and Their Suppliers
Skyworks has an established process to evaluate our products and their associated materials content. Materials and components potentially containing 3TG, and the suppliers of such materials and components, are identified on a regular basis. We survey each of these suppliers to gather sourcing information on the 3TG found in our products.
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Supplier Survey
For our supplier survey, we use the RMI’s CMRT, which was developed to facilitate disclosure and communication of information regarding smelters/refiners that provide material to a company’s supply chain. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters/refiners the company and its suppliers use. In addition, the CMRT contains questions about supplier due diligence and the origin of conflict minerals included in the supplier’s products. Written instructions and recorded training illustrating the use of the tool is available on the RMI’s website. We understand that the CMRT is being used by many companies in their due diligence processes related to conflict minerals.
Survey Results
We identified 61 direct suppliers whose materials or components contain 3TG. We rely on these suppliers to provide us with information about the source of conflict minerals contained in the materials and components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers. We conducted our supplier survey activity in the first and third quarters of calendar year 2017. We sent surveys to all identified direct suppliers of materials or components that potentially contain 3TG and we received responses from 100% of the surveyed suppliers.
After receiving completed surveys from our suppliers, we reviewed the responses against internally developed criteria to evaluate the quality of the responses and to determine which responses required further engagement with our suppliers. These criteria included untimely or incomplete responses as well as inconsistencies within the data reported in the survey. In particular, we compared the smelters/refiners identified by our suppliers against the lists of RMAP-Conformant and RMAP-Active smelters and refiners. We raised the overall data quality by working directly with those suppliers who provided incomplete or inconsistent responses to provide revised responses.
Supplier survey responses included the names of 213 confirmed smelters/refiners (each with its own RMAP-assigned smelter identification number). Of these 213, 100% had been certified, as of December 31, 2017, as RMAP-Conformant. Lists of the RMAP-Conformant smelters and refiners are available via the RMI’s website.
Efforts to Determine Mine or Location of Origin
Through our participation in the RMI and by following our established due diligence process in accordance with the OECD Guidance, we make efforts to determine “mine or location of origin” of reported conflict minerals in our supply chain through analysis of supplier survey responses, comparison of reported smelters/refiners against the lists of RMAP-Conformant and RMAP-Active smelters/refiners, and review of country-of-origin information which is made available to RMI members via the “Conformant Smelter Sourcing Information” list. These represent the most reasonable efforts we can make to determine the mines or locations of origin of the 3TG in our supply chain.
3. Implementation of a Strategy to Respond to Identified Risks
The primary focus of our efforts to date has been movement toward and maintenance of a supply chain that uses exclusively RMAP-Conformant smelters and refiners and we anticipate our focus going forward will be to maintain such a supply chain. During 2017, we successfully worked with our suppliers to address, and/or eliminate from our supply chain, any identified noncompliant smelters/refiners. To further mitigate the risk that the conflict minerals in our products could benefit armed groups in the Covered Countries, we intend to continue our membership in the RBA
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and in the RMI to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance.
In addition, we intend to continue to assist suppliers to do the following:
• | confirm that all smelters/refiners listed in their survey responses are actual confirmed smelters/refiners with verified RMI identification numbers; |
• | encourage smelters/refiners in their supply chains to be audited under the RMAP to become RMAP-Conformant; |
• | establish alternative sources of 3TG that do not support armed conflict in the Covered Countries in the event that the suppliers determine that they have been receiving 3TG from sources that support such conflict; and |
• | improve their systems of transparency and internal control to ensure the quality and reliability of the data they provide. |
4. Audit of Supply Chain Due Diligence
As noted above, we do not have a direct relationship with any smelters or refiners that are not already confirmed as RMAP-Conformant. We do not directly conduct audits. Instead, we work through our own supply chain and the RMI to create leverage and encourage smelters/refiners to subject their due diligence efforts to a third-party audit.
5. Reporting on Supply Chain Due Diligence
Our public disclosures regarding conflict mineral sourcing include this CMR filed with the SEC as an exhibit to the Specialized Disclosure Report on Form SD. This CMR is also publicly available on our website at http://www.skyworksinc.com/SustainabilityReporting.aspx.
Determination for Calendar Year 2017
On the basis of our due diligence measures as described in this CMR, we have determined in good faith, and to the best of our knowledge, that our products were DRC Conflict Free for 2017. In this regard, and as disclosed, we had a 100% 3TG supplier response rate, and our data results indicated our smelter/refiner supply chain as 100% RMAP-Conformant. The facilities the Company believes to be used to process the Company’s necessary Conflict Minerals include the smelters and refiners listed in Annex A. Countries of origin, to the best of our knowledge, are listed in Annex B.
In light of our position in the supply chain, our due diligence measure can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals in our products. We rely on our direct suppliers to provide us with information in this regard, and those suppliers, in turn, generally must seek similar information from within their supply chains to identify the original sources of the necessary Conflict Minerals. We also rely, to a significant extent, on information collected and provided by independent third party audit programs. Such sources of information may yield inaccurate or incomplete information and may be subject to fraud.
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Annex A
Subject Mineral | Smelter or Refiner Name | Country of Smelter or Refiner |
Gold | Advanced Chemical Company | UNITED STATES |
Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
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 |
Gold | Asaka Riken Co., Ltd. | JAPAN |
Gold | Aurubis AG | GERMANY |
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 | Chimet S.p.A. | ITALY |
Gold | DODUCO Contacts and Refining GmbH | GERMANY |
Gold | Dowa | JAPAN |
Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF |
Gold | Eco-System Recycling Co., Ltd. | JAPAN |
Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA |
Gold | Heimerle + Meule GmbH | GERMANY |
Gold | Heraeus Metals Hong Kong Ltd. | CHINA |
Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA |
Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
Gold | Istanbul Gold Refinery | TURKEY |
Gold | Japan Mint | JAPAN |
Gold | Jiangxi Copper Co., Ltd. | CHINA |
Gold | JSC 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 | Kyrgyzaltyn JSC | KYRGYZSTAN |
Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
Gold | Materion | UNITED STATES |
Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
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 |
Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO |
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Subject Mineral | Smelter or Refiner Name | Country of Smelter or Refiner |
Gold | Mitsubishi Materials Corporation | JAPAN |
Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY |
Gold | Nihon Material Co., Ltd. | JAPAN |
Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA |
Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
Gold | PAMP S.A. | SWITZERLAND |
Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
Gold | PX Precinox S.A. | SWITZERLAND |
Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA |
Gold | Republic Metals Corporation | UNITED STATES |
Gold | Royal Canadian Mint | CANADA |
Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
Gold | Schone Edelmetaal B.V. | NETHERLANDS |
Gold | SEMPSA Joyeria Plateria S.A. | SPAIN |
Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
Gold | Singway Technology Co., Ltd. | TAIWAN |
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 | T.C.A S.p.A | ITALY |
Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
Gold | Tokuriki Honten Co., Ltd. | JAPAN |
Gold | Torecom | KOREA, REPUBLIC OF |
Gold | Umicore Brasil Ltda. | BRAZIL |
Gold | Umicore Precious Metals Thailand | THAILAND |
Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM |
Gold | United Precious Metal Refining, Inc. | UNITED STATES |
Gold | Valcambi S.A. | SWITZERLAND |
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 |
Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
Tantalum | D Block Metals, LLC | UNITED STATES |
Tantalum | Exotech Inc. | UNITED STATES |
Tantalum | F&X Electro-Materials Ltd. | CHINA |
Tantalum | FIR Metals & Resource Ltd. | CHINA |
Tantalum | Global Advanced Metals Aizu | JAPAN |
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Subject Mineral | Smelter or Refiner Name | Country of Smelter or Refiner |
Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA |
Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
Tantalum | H.C. Starck Co., Ltd. | THAILAND |
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 | H.C. Starck Tantalum and Niobium GmbH | GERMANY |
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 Nonferrous Metals Smelting Company Limited | CHINA |
Tantalum | KEMET Blue Metals | MEXICO |
Tantalum | KEMET Blue Powder | UNITED STATES |
Tantalum | LSM Brasil S.A. | BRAZIL |
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 | Power Resources Ltd. | MACEDONIA |
Tantalum | QuantumClean | UNITED STATES |
Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION |
Tantalum | Taki Chemical Co., Ltd. | JAPAN |
Tantalum | Telex Metals | UNITED STATES |
Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN |
Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
Tin | Alpha | UNITED STATES |
Tin | China Tin Group Co., Ltd. | CHINA |
Tin | CV Ayi Jaya | INDONESIA |
Tin | CV Gita Pesona | INDONESIA |
Tin | CV Serumpun Sebalai | INDONESIA |
Tin | CV Tiga Sekawan | INDONESIA |
Tin | CV United Smelting | INDONESIA |
Tin | CV Venus Inti Perkasa | INDONESIA |
Tin | Dowa | JAPAN |
Tin | EM Vinto | BOLIVIA |
Tin | Fenix Metals | POLAND |
Tin | Gejiu Jinye Mineral Company | CHINA |
Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA |
Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA |
Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
Tin | Melt Metais e Ligas S.A. | BRAZIL |
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Subject Mineral | Smelter or Refiner Name | Country of Smelter or Refiner |
Tin | Metallic Resources, Inc. | UNITED STATES |
Tin | Metallo Belgium N.V. | BELGIUM |
Tin | Metallo Spain S.L.U. | SPAIN |
Tin | Mineracao Taboca S.A. | BRAZIL |
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 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 Prima Tin | INDONESIA |
Tin | PT Bangka Tin Industry | INDONESIA |
Tin | PT Belitung Industri Sejahtera | 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 Lautan Harmonis Sejahtera | INDONESIA |
Tin | PT Menara Cipta Mulia | 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 Stanindo Inti Perkasa | INDONESIA |
Tin | PT Sukses Inti Makmur | 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 | PT Tommy Utama | INDONESIA |
Tin | Resind Industria e Comercio Ltda. | BRAZIL |
Tin | Rui Da Hung | TAIWAN |
Tin | Soft Metais Ltda. | BRAZIL |
Tin | Thaisarco | THAILAND |
Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL |
Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
Tin | Yunnan Tin Company Limited | CHINA |
Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA |
Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
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Subject Mineral | Smelter or Refiner Name | Country of Smelter or Refiner |
Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY |
Tungsten | H.C. Starck Tungsten GmbH | GERMANY |
Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA |
Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | 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 |
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 |
Tungsten | Kennametal Huntsville | UNITED STATES |
Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA |
Tungsten | Niagara Refining LLC | UNITED STATES |
Tungsten | Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC | VIETNAM |
Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIETNAM |
Tungsten | Vietnam Youngsun Tungsten Industry Co., Ltd. | VIETNAM |
Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA |
Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA |
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Annex B
Countries of Origin
Argentina |
Australia |
Austria |
Benin |
Bolivia |
Brazil |
Burkina Faso |
Burundi |
Cambodia |
Canada |
Chile |
China |
Colombia |
Democratic Republic of Congo |
Ecuador |
Eritrea |
Ethiopia |
France |
Germany |
Ghana |
Guatemala |
Guinea |
Guyana |
Honduras |
India |
Indonesia |
Japan |
Kazakhstan |
Laos |
Madagascar |
Malaysia |
Mali |
Mexico |
Mongolia |
Mozambique |
Myanmar |
Namibia |
Nicaragua |
Nigeria |
Panama |
Peru |
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Portugal |
Russia |
Rwanda |
Senegal |
Sierra Leone |
South Africa |
Spain |
Thailand |
Togo |
Uganda |
United Kingdom |
United States of America |
Uzbekistan |
Vietnam |
Zimbabwe |
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Annex C
INDEPENDENT ACCOUNTANT’S REPORT
To Board of Directors and Shareholders of Skyworks Solutions, Inc.:
We have examined:
• | whether the design of Skyworks Solutions Inc.’s (the “Company”) due diligence framework as set forth in section 1. Design of the Conflict Minerals Program of the Conflict Minerals Report for the calendar year ended December 31, 2017 (the “Conflict Minerals Report”), 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 (the “OECD Due Diligence Guidance”), and |
• | whether the Company’s description of the due diligence measures it performed, as set forth in section 2. Due Diligence Measures Taken in 2017 Reporting Period of the Conflict Minerals Report, 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 the 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. Those standards require that we plan and perform the examination to obtain reasonable assurance about whether the design of the Company’s due diligence framework is in conformity with the OECD Due Diligence Guidance and whether the description of the due diligence measures the Company performed is consistent with the due diligence process that the Company undertook, in all material respects. An examination involves performing procedures to obtain evidence about the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed. The nature, timing and extent of the procedures selected depend on our judgment, including an assessment of the risks of material misstatement of the design of the Company’s due diligence framework and the description of the due diligence measures the Company performed, whether due to error or fraud. We believe that the evidence we obtained is sufficient and appropriate to provide a reasonable basis for our opinion.
Our examination was not conducted for the purpose of evaluating:
• | 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; |
• | 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; |
• | whether a third party can determine from the Conflict Minerals Report if the due diligence measures that the Company performed are consistent with the OECD Due Diligence Guidance; |
• | 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; or |
• | 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. |
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 sections 1. Design of the Conflict Minerals Program and 2. Due Diligence Measures Taken in 2017 Reporting Period referenced in paragraph 1 of this report.
In our opinion,
• | the design of the Company’s due diligence framework for the calendar year ended December 31, 2017, as set forth in section 1. Design of the Conflict Minerals Program 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 section 2. Due Diligence Measures Taken in 2017 Reporting Period of the Conflict Minerals Report, is consistent, in all material respects, with the due diligence process that the Company undertook. |
/s/ KPMG LLP
Atlanta, Georgia
May 31, 2018
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