SD

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM SD

 

 

SPECIALIZED DISCLOSURE REPORT

 

 

SYNAPTICS INCORPORATED

(Exact name of registrant as specified in its charter)

 

 

 

DELAWARE   000-49602   77-0118518

(State or other jurisdiction

of incorporation)

 

(Commission

File Number)

 

(I.R.S. Employer

Identification No.)

1109 McKay Drive

San Jose, California 95131

(Address of principal executive offices, including zip code)

Lisa Bodensteiner

(408) 904-1100

(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:

 

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.

Conflict Minerals Disclosure

Synaptics Incorporated (including its consolidated subsidiaries, the “Registrant”) is filing this Form SD pursuant to Rule 13p-1 under the Securities Exchange Act of 1934 for the reporting period from January 1, 2023 to December 31, 2023 (the “Reporting Period”).

For the Reporting Period, the Registrant conducted, in good faith, a reasonable country of origin inquiry regarding the conflict minerals (as defined in Item 1.01(d)(3) of Form SD), as well as cobalt, that are necessary to the functionality or production of products that the Registrant manufactures or contracts to manufacture (the “Minerals”). The inquiry was reasonably designed to determine if the Minerals originated in the Democratic Republic of the Congo or an adjoining country or are from recycled or scrap sources.

The Registrant has determined that it is required to file a Conflict Minerals Report, which is attached as Exhibit 1.01 to this report. The Conflict Minerals Report is also publicly available at https://www.synaptics.com/conflict-minerals. The content on, or accessible through, any website referred to in this Form SD is not incorporated by reference into this Form SD unless expressly noted.

 

Item 1.02.

Exhibit.

The Registrant’s Conflict Minerals Report is included as Exhibit 1.01 to this report.

Section 2 – Exhibits

 

Item 2.01.

Exhibits.

 

Exhibit
Number
  

Description

1.01    Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.


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.

 

Synaptics Incorporated
By:   /s/ Lisa Bodensteiner
Lisa Bodensteiner
Senior Vice President and Chief Legal Officer
May 31, 2024
EX-1.01

EXHIBIT 1.01

CONFLICT MINERALS REPORT

This Conflict Minerals Report (“Report”) of Synaptics Incorporated and its consolidated subsidiaries (“Synaptics,” the “Registrant,” or “we”) for the calendar year ended December 31, 2023 (the “Reporting Period”), is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”), the instructions to Form SD, and the Public Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule issued by the Director of the Division of Corporation Finance of the Securities and Exchange Commission on April 29, 2014. Please refer to the Rule, Form SD, and the Securities and Exchange Commission’s (“SEC”) Release No. 34-67716 issued by the SEC on August 22, 2012, for definitions to the terms used in this Report, unless otherwise defined herein.

Synaptics is changing the way humans engage with connected devices and data, engineering exceptional experiences throughout the home, at work, in the car and on the go. Synaptics is the partner of choice for the world’s most innovative intelligent system providers who are integrating multiple experiential technologies into platforms that make our digital lives more productive, insightful, secure and enjoyable. These customers are combining Synaptics’ differentiated technologies in touch, display and biometrics with a new generation of advanced connectivity and artificial intelligence-, or AI, enhanced video, vision, audio, speech and security processing. We generally supply our product solutions to our original equipment manufacturer (“OEM”) customers either directly or through their contract manufacturers, which take delivery of our products and pay us directly for such products.

Synaptics does not engage in the actual mining of conflict minerals or cobalt (the “Minerals”), does not make purchases of raw ore or unrefined Minerals from mines, and is many steps removed in the supply chain from the mining of the Minerals. We purchase the materials used in our products from a large network of suppliers, who may contribute necessary Minerals to our products. The smelters and refiners used by our suppliers are in the best position in the total supply chain to know the origin of ores, which cannot be determined with any certainty once the ores are smelted, refined and converted to ingots, bullions or other Minerals-containing derivatives. We rely on our suppliers to assist with our due diligence efforts, including our suppliers’ self-identification of the smelters and refiners used in their supply chain, and the countries from which the Minerals used in their supply chain may originate.


  II.

Products

The following products were identified during the Reporting Period as products that may contain any of the Minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by Synaptics:

 

   

Our AstraTM platform is a scalable portfolio of intelligent edge processors, ranging from highly integrated microprocessor units, or MPUs, to high-performance microcontroller units, or MCUs, architected for an AI-enabled Internet of Things, or IoT. Supported by the Astra platform, the Synaptics SL and SR Series of AI-native System-on-a-Chip, or SoC, integrated circuits deliver a unified experience combining standards-based open software frameworks, rapid prototyping kits, full-featured AI/machine learning, or ML, toolkits, and Synaptics’ best-in-class Wi-Fi and Bluetooth connectivity solutions.

 

   

Our ClearPad® family of products enables the user to interact directly with the display on electronic devices, such as mobile smartphones, tablets, and automobiles. Our ClearPad has distinct advantages, including low-profile form factor; high reliability, durability, and accuracy; and low power consumption. We typically sell our ClearPad solution as a chip, together with customer-specific firmware, to sensor manufacturers, OLED manufacturers or LCD manufacturers, to integrate into their touch-enabled products.

 

   

Our ClearViewTM display driver products offer advanced image processing and low power technology for displays on electronic devices, including smartphones and tablets. ClearView products include adaptive image processing that works in concert with proprietary customization options to enable development of efficient and cost-effective high-performance solutions and faster time to market. Our display driver products offer automatic regional control of color balance that optimizes light and dark areas of an image simultaneously, and sunlight readability enhancement capabilities that optimize image quality under various lighting conditions. Our virtual reality bridge and virtual reality display driver integrated circuit, or DDIC, chips enable our customers to move to higher resolution and faster response displays.

 

   

Our TouchViewTM solutions include our TDDI products that combine two functions, a touch controller, and a display driver, into a single chip that incorporates all the features of our ClearView and ClearPad products. TouchView products enable thinner form factors to help customers minimize component count and add flexibility to their industrial designs. These products are used in large screen devices, including notebooks and tablets, and are also certified for automotive display applications.

 

   

Our Natural ID® family of capacitive-based fingerprint ID products is designed for use in notebook PCs, PC peripherals, automobiles, and other applications. Thin form factors provide industrial design flexibility, while robust matching algorithms and anti-spoofing technology provide strong security. Our Natural ID family of products spans a range of form factors, colors, and materials suitable for design on the front, back or side of a device.

 

   

Our TouchPadTM family of products, which can take the place of, and exceed the functionality of a mouse, consists of a touch-sensitive pad that senses the position and movement of one or more fingers on its surface through the measurement of capacitance. Our TouchPad provides an accurate, comfortable, and reliable method for screen navigation, cursor movement, and gestures, and provides a platform for interactive input for both the consumer and corporate markets. Our TouchPad solutions allow our OEMs to provide stylish, simple, user-friendly, and intuitive solutions to consumers. Our TouchPad solutions also offer various advanced features, including scrolling, customizable tap zones, tapping and dragging of icons, and device interaction.

 

   

Our SecurePadTM integrates our Natural ID fingerprint sensor directly into the TouchPad area, improving usability and simplifying the supply chain for notebook PC manufacturers.


   

Our ClickPadTM introduces a clickable mechanical design to the TouchPad solution, eliminating the need for physical buttons. The button-less design of our ClickPad allows for unique, intuitive industrial design and makes an excellent alternative to conventional input and navigation devices. Our ClickPad is activated by pressing down on the internal tact switch to perform left-button or right-button clicks and provides tactile feedback similar to pressing a physical button. The latest version of ClickPad features ClickEQTM, a mechanical solution that provides uniform click depth to maximize the surface area available for gestures and improves click performance over hinged designs.

 

   

Our ForcePad® is a thinner version of our ClickPad, which introduces a new dimension in control through the addition of variable force sensitivity. ForcePad is designed to provide consistent performance across OEM models through its design intelligence and self-calibration features. By detecting the amount of force applied, ForcePad is engineered to enable more intuitive and precise user interactions in operating system controls and applications. Designed with thin and light notebooks in mind, ForcePad is 40% thinner than a conventional touch pad.

 

   

Our Digital Voice Family, or DVF, of SoC products is a comprehensive solution for developing affordable, scalable and green Voice over IP, or VoIP, home and office products. DVF facilitates rapid introduction of embedded features into residential devices such as cordless IP and instant messaging phones. DVF enables development of low-power enterprise IP, analog terminal adapters, or ATAs, and home VoIP phones that offer superb acoustic echo cancellation, high-quality HD voice, multi-line capabilities, and an enhanced user interface. Built on an open platform with multi-ARM processors running on Linux OS, DVF includes IPfonePro, an extensive software development kit for IP phones and ATAs.

 

   

Our Digital Enhanced Cordless Telecommunications, or DECT, SoC solutions provide integrated digital solutions and include all relevant digital baseband, analog interface and radio frequency functionality. Enhanced with our hardware and software technologies, these chipsets are highly versatile and enable the development of an array of cordless telephony solutions that allow for faster time to market than alternative custom silicon and software offerings. This portfolio supports cordless phones, cordless headsets, remote controls, home DECT-enabled gateways, fixed-mobile convergence solutions and home automation devices.

 

   

Our AudioSmart® products bring forward optimum analog, mixed-signal and digital signal processor, or DSP, technologies for high-fidelity voice and audio processing. Our AudioSmart products include far-field voice technologies that enable accurate voice command recognition from a distance while disregarding other sounds, such as music, in order to activate smart devices such as smart speakers. AudioSmart also includes personal voice and audio solutions for high-performance headsets that enable active noise cancellation.


   

Our VideoSmartTM series SoCs include CPUs running at up to 40K Dhrystone Million Instructions per Second, gaming-grade graphics processing units, or GPUs, voice, and neural network processing units, or NPU. These powerful solutions combine a central processing unit, or CPU, NPU, and GPU, into a single software-enriched SoC. They enable smart multimedia devices including set-top boxes, or STB, over-the-top, or OTT, streaming devices, soundbars, surveillance cameras and smart displays.

 

   

Our ImagingSmartTM solutions include a product portfolio that spans four distinct product areas including document and photo imaging controllers, digital video, fax, and modem solutions. ImagingSmart products leverage image processing IP, JPEG encoders and DSP technology to deliver a wide range of fax, modem, digital video and printer solutions for home, mobile and imaging applications.

 

   

Our DisplayLink® products utilize highly efficient video encode/decode algorithms to deliver a semiconductor-based solution which transmits compressed video frames across low bandwidth connections. These solutions are used in PC docking applications, conference room video display systems, and video casting applications.

 

   

Our ConnectSmartTM video interface integrated circuit portfolio offers a full range of high-speed video/audio/data connectivity solutions that are designed for linking CPUs/GPUs and various endpoints for applications including PC docking stations, travel docks, dongles, protocol converters and virtual reality head mounted displays.

 

   

Our wireless connectivity solutions include state-of-the-art Wi-Fi, Bluetooth, GPS, GNSS, and ULE to address broad IoT market applications including home automation, multimedia streamers, security sensors, surveillance cameras, wireless speakers, games, drones, printers, wearable and fitness devices, in addition to numerous other applications which require a wireless connection.

 

   

Our ultra-low power edge AI platform includes a highly integrated edge AI SoC designed for battery powered wireless devices equipped with audio or camera capabilities for consumer and industrial IoT applications. These solutions are designed for a wide range of power constrained IoT applications used in office buildings, retail, factories, warehouses, robotics, and smart homes and cities.

 

   

Other product solutions we offer include Dual Pointing Solutions, and TouchStykTM. Our dual pointing solutions offer TouchPad with a pointing stick in a single notebook computer, enabling users to select their interface of choice. TouchStyk is a self-contained pointing stick module that uses capacitive technology similar to that used in our TouchPad.


  III.

Due Diligence

Based on the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (Third Edition OECD 2016) and the due diligence framework published by the Responsible Business Alliance (“RBA”) and the Global e-Sustainability Initiative (“GeSI”), including the Responsible Minerals Initiative’s (“RMI”) Conflict Minerals Reporting Template for calendar year 2023 (the “Template”), we took the following measures, during the Reporting Period, to determine the source and chain of custody for the Minerals which we believed necessary to the functionality or production of products manufactured, or contracted to be manufactured, by us in the Reporting Period.

 

  1.

Synaptics identified 91 suppliers, whom we believed could provide materials containing the Minerals necessary to the functionality or production of products manufactured by us or contracted by us to be manufactured.

 

  2.

Synaptics sent out a survey, based on the Template, to the suppliers described in No. 1 above requesting them to (a) determine whether they supplied Synaptics with metals or materials containing the Minerals; (b) conduct independent due diligence on their own supply chain; (c) identify all smelters in their supply chain that supply products containing the Minerals to Synaptics; and (d) download, complete and return the Template to Synaptics identifying all smelters and, using RMI resources, determine whether such smelters were certified as conformant smelters by the RMI’s Responsible Minerals Assurance Process (“RMAP”). For any non-conformant smelters identified, Synaptics strongly recommended the supplier remove such non-conformant smelter from the supplier’s supply chain and required the supplier to submit a plan to Synaptics detailing its efforts to remove or replace the non-conformant smelter. In addition, Synaptics’ suppliers were required to establish and document a policy on conflict minerals.

 

  3.

100% of the suppliers identified in No. 1 above completed the steps described in No. 2 above, and 20 suppliers declared that their products did not contain any of the Minerals. Of the 71 suppliers who stated their products may contain the Minerals, approximately 52% stated gold may be in the products supplied to Synaptics; approximately 62% stated tin may be in the products supplied to Synaptics; approximately 22% stated tantalum may be in the products supplied to Synaptics; approximately 31% stated tungsten may be in the products supplied to Synaptics; approximately 4% stated cobalt may be in the products supplied to Synaptics.

 

  4.

All of the suppliers who responded identified all of the smelters used in their supply chain, in accordance with the Template and its instructions. The 71 suppliers sourced conflict minerals from a combined 272 different smelters, of which 18 smelters were non-conformant smelters, as determined by the RMAP.1

 

1 

Smelter data presented in this Report is based on the Responsible Minerals Assurance Process list of Conformant Smelters and Refiners as of March 19, 2024.


  5.

Synaptics compared the smelters identified by each of our suppliers to the list of smelters identified as conformant smelters by the RMAP. Approximately 98% of the smelters used by our suppliers for tantalum, gold, tin and tungsten appeared on this list and are certified by the RMAP as conformant smelters. Based on the information provided by our suppliers, Synaptics believes that the facilities used to process the Minerals contained in Synaptics’ products include the smelters listed in Exhibit A below.

 

  a.

Our suppliers used 32 different smelters located in 10 different countries for tantalum. These countries include Brazil, China, Estonia, Germany, India, Japan, Kazakhstan, Mexico, Thailand and the United States of America. Of these smelters, 100% are certified conformant smelters as defined by the RMAP.

 

  b.

Our suppliers used 91 different smelters located in 31 different countries for gold. These countries include Andorra, Australia, Austria, Belgium, Brazil, Canada, Chile, China, Colombia, Czechia, France, Germany, India, Indonesia, Italy, Japan, Kazakhstan, Mexico, Netherlands, Philippines, Poland, Republic of Korea, Singapore, South Africa, Spain, Sweden, Switzerland, Taiwan, Turkey, the United States of America, and Uzbekistan. Of these smelters, approximately 98% are certified conformant smelters as defined by the RMAP.

 

  c.

Our suppliers used 67 different smelters located in 17 different countries for tin. These countries include Belgium, Bolivia, Brazil, China, India, Indonesia, Japan, Malaysia, Myanmar, Peru, the Philippines, Poland, Rwanda, Spain, Taiwan, Thailand, and the United States of America. Of these smelters, approximately 99% are certified conformant smelters as defined by the RMAP.

 

  d.

Our suppliers used 32 different smelters located in 9 different countries for tungsten. These countries include Austria, Brazil, China, Germany, Japan, the Philippines, Taiwan, the United States of America, and Vietnam. Of these smelters, approximately 97% are certified conformant smelters as defined by the RMAP.


  6.

Our suppliers used 50 different smelters located in 13 different countries for cobalt. These countries include Australia, Belgium, Canada, China, Democratic Republic of the Congo, Finland, Indonesia, Japan, Madagascar, Morocco, Norway, Russian Federation, South Korea, Taiwan, Thailand, and the United Kingdom of Great Britain and Northern Ireland. RMI has begun to assess whether cobalt smelters and refiners are conformant with applicable RMAP protocols; however, the operational impacts of Covid-19 have continued to cause delays with some RMAP assessments. As of May 22, 2024, RMI has reported 46 cobalt smelters and refiners as conformant with applicable RMAP assessment protocols and 19 cobalt smelters and refiners that are active with respect to progressing to compliance with such protocols. Of the 50 smelters that our suppliers used, 39 are certified conformant smelters as defined by RMAP and 5 are active with respect to progressing to conformant status. We continue to encourage the cobalt refiners in our supply chain to participate in the RMAP process.

 

  7.

Synaptics’ reasonable country of origin inquiry and due diligence efforts are based on surveys provided by its suppliers, which report to Synaptics whether its smelters are certified as conformant smelters. Certain of Synaptics’ suppliers were unable to determine the countries of origin of the Minerals it provided to us, therefore, we are unable, at this time, to conclusively determine the countries of origin of all the Minerals used in our products.

During the Reporting Period, we conducted the due diligence efforts described in this Report to determine the mine or location of the Minerals in our products. We relied on the information provided by independent third-party audit programs, such as the RMI, to determine whether the smelters disclosed by our suppliers are conformant smelters, as defined by the RMAP.

We continue to recommend to, and put pressure on, our suppliers who had non-conformant smelters in their supply chain in calendar year 2023 to remove such non-conformant smelters from their supply chain as soon as possible and we require such suppliers to submit a plan to Synaptics detailing their efforts to either remove or replace such smelter.

As discussed above, where possible, Synaptics has relied on third party assurances and certifications. For example, we accept as reliable any smelter that is identified as conformant by the RMAP. To the extent that other audited supplier certifications are provided to Synaptics, Synaptics may consider reliance on such certifications on a case-by-case basis.

 

IV.

Additional Due Diligence and Risk Mitigation

Synaptics periodically assesses the risk of other minerals in its products, and we update our due diligence process to address the risk of additional minerals, when appropriate.


We will continue to monitor our supply chain, including smelters used by our suppliers, to ensure that all smelters used by our suppliers are conformant with the RMAP. We will continue to pressure our supply chain to provide complete and accurate information regarding their smelters who provide the Minerals; continue to pressure our supply chain to either remove or replace non-conformant smelters from their own supply chain; remove from our supply chain those suppliers who continually refuse to or who are unable to provide complete information regarding their smelters; remove from our supply chain those suppliers who continue to maintain non-conformant smelters in their supply chain; and assess the results of supplier responses to the Template.

Due to the size, breadth and complexity of our supply chain, the process of successfully tracing all of the necessary Minerals used in our products back to their country of origin will require additional time and resources. Our ability to make determinations about the presence and source of origin of such Minerals in our products depends upon a number of factors including, but not limited to: (i) the respective due diligence efforts of our suppliers and their supply chain, as well as their willingness to disclose such information to us, and (ii) the ability and willingness of our supply chain to adopt the OECD Guidance and other initiatives or guidance that may develop over time with respect to responsible sourcing. The inability to obtain reliable information from any level of our supply chain could have a material impact on our ability to provide meaningful information on the presence and origin of necessary Minerals in our products’ supply chain with any reasonable degree of certainty. There can be no assurance that our suppliers will continue to cooperate with our diligence inquiries and our requests for certifications, or to provide us with the documentation or other evidence that we consider reliable in a timeframe sufficient to allow us to make a reasonable and reliable assessment following appropriate further diligence measures, as may be required.


Exhibit A

Smelters reported in Synaptics’ Supply Chain as of December 31, 2023:

 

Smelter Name

  

Smelter Country

A.L.M.T. Corp.    Japan
Advanced Chemical Company    United States Of America
Agosi AG    Germany
Aida Chemical Industries Co., Ltd.    Japan
Almalyk Mining and Metallurgical Complex (AMMC)    Uzbekistan
Alpha    United States Of America
AMG Brasil    Brazil
AngloGold Ashanti Corrego do Sitio Mineracao    Brazil
Anhui Hanrui New Material Co., Ltd.    China
Argor-Heraeus S.A.    Switzerland
Asahi Pretec Corp.    Japan
Asahi Refining Canada Ltd.    Canada
Asahi Refining USA Inc.    United States Of America
Asaka Riken Co., Ltd.    Japan
Asia Tungsten Products Vietnam Ltd.    Viet Nam
Augmont Enterprises Private Limited    India
Aurubis AG    Germany
Aurubis Beerse    Belgium
Aurubis Berango    Spain
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)    Philippines
Boliden AB    Sweden
C. Hafner GmbH + Co. KG    Germany
CCR Refinery—Glencore Canada Corporation    Canada
Changsha South Tantalum Niobium Co., Ltd.    China
Chemaf Etoile    Democratic Republic Of The Congo
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.    China
Chifeng Dajingzi Tin Industry Co., Ltd.    China
Chimet S.p.A.    Italy
China Molybdenum Tungsten Co., Ltd.    China
China Tin Group Co., Ltd.    China
Chizhou CN New Materials and Technology Co., Ltd.    China
Chongyi Zhangyuan Tungsten Co., Ltd.    China
Chugai Mining    Japan


Compagnie de Tifnout Tiranimine    Morocco
CoreMax Corporation    Taiwan
Cosmo Chemical, Ltd.    Republic Of Korea
CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda    Brazil
CRM Synergies    Spain
Cronimet Brasil Ltda    Brazil
CV Ayi Jaya    Indonesia
CV Venus Inti Perkasa    Indonesia
D Block Metals, LLC    United States Of America
DARUKA MINCHEM PVT.LTD    India
Dowa    Japan
DS Myanmar    Myanmar
DSC (Do Sung Corporation)    Republic Of Korea
Dynatec Madagascar Company    Madagascar
Eco-System Recycling Co., Ltd. East Plant    Japan
Eco-System Recycling Co., Ltd. North Plant    Japan
Eco-System Recycling Co., Ltd. West Plant    Japan
EM Vinto    Bolivia (Plurinational State Of)
Estanho de Rondonia S.A.    Brazil
F&X Electro-Materials Ltd.    China
Fabrica Auricchio Industria e Comercio Ltda.    Brazil
Fenix Metals    Poland
FIR Metals & Resource Ltd.    China
Fujian Evergreen New Energy Technology Co.    China
Fujian Xinlu Tungsten Co., Ltd.    China
Ganzhou Yi Hao Umicore Industry Co.    China
Ganzhou Haichuang Tungsten Co., Ltd.    China
Ganzhou Highpower Technology Co., Ltd.    China
Ganzhou Jiangwu Ferrotungsten Co., Ltd.    China
Ganzhou Seadragon W & Mo Co., Ltd.    China
Ganzhou Tengyuan Cobalt New Material Co., Ltd.    China
Gejiu Non-Ferrous Metal Processing Co., Ltd.    China
Gem (Jiangsu) Cobalt Industry Co., Ltd.    China
GGC Gujrat Gold Centre Pvt. Ltd.    India
Glencore Nikkelverk Refinery    Norway
Global Advanced Metals Aizu    Japan
Global Advanced Metals Boyertown    United States Of America


Global Tungsten & Powders Corp.    United States Of America
Gold by Gold Colombia    Colombia
Gold Refinery of Zijin Mining Group Co., Ltd.    China
Guangdong Fangyuan Environment Co., Ltd.    China
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.    China
Guangdong Jiana Energy Technology Co., Ltd.    China
Guangdong Xianglu Tungsten Co., Ltd.    China
Guangxi Yinyi Advanced Material Co., Ltd.    China
Guizhou CNGR Resource Recycling Industry Development Co., Ltd.    China
H.C. Starck Tungsten GmbH    Germany
Harima Refinery, Sumitomo Metal Mining    Japan
Heimerle + Meule GmbH    Germany
Hengyang King Xing Lifeng New Materials Co., Ltd.    China
Heraeus Germany GmbH Co. KG    Germany
Heraeus Metals Hong Kong Ltd.    China
Hubei Green Tungsten Co., Ltd.    China
HuiChang Hill Tin Industry Co., Ltd.    China
Hunan Chenzhou Mining Co., Ltd.    China
Hunan CNGR New Energy Science & Technology Co., Ltd.    China
Hunan Jinxin New Material Holding Co., Ltd.    China
Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch    China
Hunan Yacheng New Materials Co., Ltd.    China
ICoNiChem    United Kingdom Of Great Britain And Northern Ireland
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.    China
Ishifuku Metal Industry Co., Ltd.    Japan
Istanbul Gold Refinery    Turkey
Italpreziosi    Italy
Japan Mint    Japan
Japan New Metals Co., Ltd.    Japan
Jiangsu Xiongfeng Technology Co., Ltd.    China
Jiangwu H.C. Starck Tungsten Products Co., Ltd.    China
Jiangxi Copper Co., Ltd.    China
Jiangxi Dinghai Tantalum & Niobium Co., Ltd.    China
Jiangxi Gan Bei Tungsten Co., Ltd.    China
Jiangxi Jiangwu Cobalt industrial Co., Ltd.    China


Jiangxi Miracle Golden Tiger Cobalt Co. Ltd.    China
Jiangxi New Nanshan Technology Ltd.    China
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.    China
Jiangxi Tuohong New Raw Material    China
Jiangxi Xinsheng Tungsten Industry Co., Ltd.    China
Jiangxi Yaosheng Tungsten Co., Ltd.    China
Jingmen GEM Co., Ltd.    China
JiuJiang JinXin Nonferrous Metals Co., Ltd.    China
Jiujiang Tanbre Co., Ltd.    China
Jiujiang Zhongao Tantalum & Niobium Co., Ltd.    China
JX Nippon Mining & Metals Co., Ltd.    Japan
Kamoto Copper Company    Democratic Republic Of The Congo
Kazzinc    Kazakhstan
KEMET de Mexico    Mexico
Kennametal Fallon    United States Of America
Kennametal Huntsville    United States Of America
Kennecott Utah Copper LLC    United States Of America
KGHM Polska Miedz Spolka Akcyjna    Poland
Kojima Chemicals Co., Ltd.    Japan
Korea Zinc Co., Ltd.    Republic Of Korea
La Compagnie de Traitement des Rejets de Kingamyambo S.A. (Metalkol S.A.)    Democratic Republic Of The Congo
Lanzhou Jinchuan Advanced Materials Technology Co., Ltd.    China
Lianyou Metals Co., Ltd.    Taiwan
L’Orfebre S.A.    Andorra
LS-NIKKO Copper Inc.    Republic Of Korea
LT Metal Ltd.    Republic Of Korea
Luna Smelter, Ltd.    Rwanda
Magnu’s Minerais Metais e Ligas Ltda.    Brazil
Malaysia Smelting Corporation (MSC)    Malaysia
Malipo Haiyu Tungsten Co., Ltd.    China
Masan High-Tech Materials    Viet Nam
Materion    United States Of America
Materion Newton Inc.    United States Of America
Matsuda Sangyo Co., Ltd.    Japan
Mechema Taiwan Plant 2    Taiwan
Metal Concentrators SA (Pty) Ltd.    South Africa
Metallic Resources, Inc.    United States Of America


Metallurgical Products India Pvt., Ltd.    India
Metalor Technologies (Hong Kong) Ltd.    China
Metalor Technologies (Singapore) Pte., Ltd.    Singapore
Metalor Technologies (Suzhou) Ltd.    China
Metalor Technologies S.A.    Switzerland
Metalor USA Refining Corporation    United States Of America
Metalurgica Met-Mex Penoles S.A. De C.V.    Mexico
Mine de Bou-Azzer    Morocco
Mineracao Taboca S.A.    Brazil
Minsur    Peru
Mitsubishi Materials Corporation    Japan
Mitsui Mining and Smelting Co., Ltd.    Japan
MKS PAMP SA    Switzerland
MMTC-PAMP India Pvt., Ltd.    India
Murrin Murrin Nickel Cobalt Plant    Australia
Nadir Metal Rafineri San. Ve Tic. A.S.    Turkey
Navoi Mining and Metallurgical Combinat    Uzbekistan
NH Recytech Company    Republic Of Korea
Niagara Refining LLC    United States Of America
Nihon Material Co., Ltd.    Japan
Niihama Nickel Refinery, Sumitomo Metal Mining    Japan
Ningbo Hubang New Material Co., Ltd.    China
Ningxia Orient Tantalum Industry Co., Ltd.    China
NORILSK NICKEL HARJAVALTA OY    Finland
NPM Silmet AS    Estonia
O.M. Manufacturing (Thailand) Co., Ltd.    Thailand
O.M. Manufacturing Philippines, Inc.    Philippines
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH    Austria
Ohura Precious Metal Industry Co., Ltd.    Japan
Operaciones Metalurgicas S.A.    Bolivia (Plurinational State Of)
Philippine Chuangxin Industrial Co., Inc.    Philippines
Planta Recuperadora de Metales SpA    Chile
Port Colborne Refinery    Canada
Precious Minerals and Smelting Limited    India
PT Aneka Tambang (Persero) Tbk    Indonesia
PT Aries Kencana Sejahtera    Indonesia
PT Artha Cipta Langgeng    Indonesia
PT ATD Makmur Mandiri Jaya    Indonesia


PT Babel Inti Perkasa    Indonesia
PT Babel Surya Alam Lestari    Indonesia
PT Bangka Prima Tin    Indonesia
PT Bangka Serumpun    Indonesia
PT Belitung Industri Sejahtera    Indonesia
PT Bukit Timah    Indonesia
PT Cipta Persada Mulia    Indonesia
PT Menara Cipta Mulia    Indonesia
PT Mitra Stania Prima    Indonesia
PT Mitra Sukses Globalindo    Indonesia
PT Premium Tin Indonesia    Indonesia
PT Prima Timah Utama    Indonesia
PT Putera Sarana Shakti (PT PSS)    Indonesia
PT Rajawali Rimba Perkasa    Indonesia
PT Rajehan Ariq    Indonesia
PT Refined Bangka Tin    Indonesia
PT Sariwiguna Binasentosa    Indonesia
PT Stanindo Inti Perkasa    Indonesia
PT Sukses Inti Makmur    Indonesia
PT Timah Nusantara    Indonesia
PT Timah Tbk Kundur    Indonesia
PT Timah Tbk Mentok    Indonesia
PT Tinindo Inter Nusa    Indonesia
PT Tommy Utama    Indonesia
PX Precinox S.A.    Switzerland
QuantumClean    United States Of America
Quzhou Huayou Cobalt New Material Co., Ltd.    China
Rand Refinery (Pty) Ltd.    South Africa
REMONDIS PMR B.V.    Netherlands
Resind Industria e Comercio Ltda.    Brazil
RFH Yancheng Jinye New Material Technology Co., Ltd.    China
Royal Canadian Mint    Canada
Rui Da Hung    Taiwan
SAFINA A.S.    Czechia
SEMPSA Joyeria Plateria S.A.    Spain
Shandong Gold Smelting Co., Ltd.    China
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.    China
Sichuan Tianze Precious Metals Co., Ltd.    China


SOCIETE MINIERE DU KATANGA (SOMIKA SARL)    Democratic Republic Of The Congo
Societe pour le Traitment du Terril de Lubumbashi (STL)    Democratic Republic Of The Congo
Solar Applied Materials Technology Corp.    Taiwan
Sumitomo Metal Mining Co., Ltd.    Japan
SungEel HiMetal Co., Ltd.    Republic Of Korea
SungEel HiTech Co., Ltd.    Republic Of Korea
Super Ligas    Brazil
T.C.A S.p.A    Italy
Taki Chemical Co., Ltd.    Japan
Tanaka Kikinzoku Kogyo K.K.    Japan
TANIOBIS Co., Ltd.    Thailand
TANIOBIS GmbH    Germany
TANIOBIS Japan Co., Ltd.    Japan
TANIOBIS Smelting GmbH & Co. KG    Germany
Telex Metals    United States Of America
Tenke Fungurume Mining SA    Democratic Republic Of The Congo
Thaisarco    Thailand
Tianjin Maolian Science & Technology Co., Ltd.    China
Tin Smelting Branch of Yunnan Tin Co., Ltd.    China
Tin Technology & Refining    United States Of America
Tokuriki Honten Co., Ltd.    Japan
TOO Tau-Ken-Altyn    Kazakhstan
Torecom    Republic Of Korea
Ulba Metallurgical Plant JSC    Kazakhstan
Umicore Finland Oy    Finland
Umicore Olen    Belgium
Umicore S.A. Business Unit Precious Metals Refining    Belgium
United Precious Metal Refining, Inc.    United States Of America
Valcambi S.A.    Switzerland
Vital Materials Plant    China
WEEEREFINING    France
Western Australian Mint (T/a The Perth Mint)    Australia
White Solder Metalurgia e Mineracao Ltda.    Brazil
WIELAND Edelmetalle GmbH    Germany
Wolfram Bergbau und Hutten AG    Austria
Xiamen Tungsten (H.C.) Co., Ltd.    China
Xiamen Tungsten Co., Ltd.    China
XIMEI RESOURCES (GUANGDONG) LIMITED    China


Yamaguchi Mica    Japan
Yamakin Co., Ltd.    Japan
Yanling Jincheng Tantalum & Niobium Co., Ltd.    China
Yokohama Metal Co., Ltd.    Japan
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.    China
Yunnan Yunfan Non-ferrous Metals Co., Ltd.    China
Zhejiang Greatpower Cobalt Materials Co., Ltd.    China
Zhejiang Huayou Cobalt Company Limited    China
Zhejiang New Era Zhongneng Technology Co., Ltd.    China
Zhejiang Power New Energy Materials Co., Ltd.    China
Zhongyuan Gold Smelter of Zhongjin Gold Corporation    China
Zhuhai Kelixin Metal Materials Co., Ltd.    China

SPECIAL NOTE REGARDING FORWARD-LOOKING STATEMENTS

This website contains forward-looking statements that are subject to the safe harbors created under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended. Forward-looking statements give our current expectations and projections relating to our financial condition, results of operations, plans, objectives, future performance and business, and can be identified by the fact that they do not relate strictly to historical or current facts. Such forward-looking statements may include words such as "expect," "anticipate," "intend," "believe," "estimate," "plan," "target," "strategy," "continue," "may," "will," "should," variations of such words, or other words and terms of similar meaning. All forward-looking statements reflect our best judgment and are based on several factors relating to our operations and business environment, all of which are difficult to predict and many of which are beyond our control. Such factors include, but are not limited to, the risks as identified in the "Risk Factors," "Management's Discussion and Analysis of Financial Condition and Results of Operations" and "Business" sections of our Annual Report on Form 10-K for our most recent fiscal year, and other risks as identified from time to time in our Securities and Exchange Commission reports. Forward-looking statements are based on information available to us on the date hereof, and we do not have, and expressly disclaim, any obligation to publicly release any updates or any changes in our expectations, or any change in events, conditions, or circumstances on which any forward-looking statement is based. Our actual results and the timing of certain events could differ materially from the forward-looking statements. These forward-looking statements do not reflect the potential impact of any mergers, acquisitions, or other business combinations that had not been completed as of the date of this filing.