UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
Mobileye Global Inc.
(Exact name of the registrant as specified in its charter)
| Delaware | 001-41501 |
|
(State or other jurisdiction of incorporation) |
(Commission File Number) |
|
c/o Mobileye B.V. Har Hotzvim, 13 Hartom Street P.O. Box 45157 Jerusalem, Israel |
9777513 |
| (Address of principal executive offices) | (Zip code) |
|
Liz Cohen-Yerushalmi +972-2-541-7333 |
|
| (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:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2022 |
| ¨ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the reporting period from January 1 to December 31, 2022 |
SECTION 1 – CONFLICT MINERALS DISCLOSURE
| Item 1.01 | Conflict Minerals Disclosure and Report |
Conflict Minerals Disclosure
This Specialized Disclosure Report on Form SD and the Conflict Minerals Report, filed as Exhibit 1.01 hereto, are publicly available at https://ir.mobileye.com/financial-information/sec-filings and https://ir.mobileye.com/corporate-governance/governance-overview as well as the SEC’s EDGAR database at www.sec.gov. The information contained on the Company’s website is not a part of this Form SD and is not deemed incorporated by reference into this Form SD or any other public filing made with the SEC.
| Item 1.02 | Exhibit |
The Conflict Minerals Report required by Item 1.01 is filed as Exhibit 1.01 to this Form SD.
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 SD.
2
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.
| Mobileye Global Inc. (Registrant) |
|||
| By: | /s/ Professor Amnon Shashua | May 30th, 2023 | |
| Professor Amnon Shashua Chief Executive Officer and President |
Date | ||
3
Exhibit 1.01
Conflict Minerals Report
Mobileye Global Inc.
in accord with Rule 13p-1 under the Securities Exchange Act of 1934
This Conflict Minerals Report (Report) of Mobileye Global Inc. (“Mobileye” or “we”) for the year ended December 31, 2022 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the Rule). The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting requirements related to “conflict minerals,” defined by the SEC as columbite-tantalite (coltan), cassiterite, gold, wolframite, and their derivatives, which are currently limited to tantalum, tin, and tungsten.
The Rule imposes certain reporting obligations on SEC registrants whose products contain conflict minerals that are necessary to the functionality or production of their products (referred to as “conflict minerals”). For products that contain necessary conflict minerals, the registrant must conduct in good faith a reasonable country of origin inquiry designed to determine whether any of the necessary conflict minerals originated in the Democratic Republic of the Congo (DRC) or an adjoining country (collectively, the “Covered Countries”). If, based on such inquiry, the registrant knows or has reason to believe that any of the necessary conflict minerals originated or may have originated in a Covered Country and may not be solely from recycled or scrap sources, the registrant must conduct due diligence to determine if the necessary conflict minerals directly or indirectly financed or benefited armed groups (as defined by the SEC in Form SD) in the Covered Countries.
Forward-Looking Statements
We caution that any forward-looking statements (as such term is defined in the Private Securities Litigation Reform Act of 1995) contained in this Conflict Minerals Report involve risks and uncertainties and are subject to change based on various factors, many of which are beyond our control. Among the factors that could cause actual results to differ materially are the risks and uncertainties set forth in “Item 1A. Risk Factors” in our 2022 Annual Report on Form 10-K filed with the SEC on March 9, 2023. We are not under any obligation and do not intend to make publicly available any update or other revisions to any of the forward-looking statements contained in this Conflict Minerals Report to reflect circumstances existing after the date of this report or to reflect the occurrence of future events even if experience or future events make it clear that any expected results expressed or implied by those forward-looking statements will not be realized.
Overview of Mobileye’s Responsible Minerals Program and Commitment to Responsible Sourcing
As set forth in our Responsible Minerals Sourcing Policy, Mobileye is committed to the responsible sourcing of conflict minerals, which we define as sourcing done in an ethical and sustainable manner that safeguards the human rights of everyone in our global supply chain. Mobileye’s responsible minerals program examines human rights risks in Conflict-Affected and High-Risk Areas (CAHRAs) globally, as defined by the Organisation 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, and related Supplements on Tin, Tantalum and Tungsten and on Gold (collectively, “OECD Guidance”).
Many of our hardware products contain tantalum, tin, tungsten and/or gold ("3TG") necessary to the functionality or production of those products. Conflict minerals are obtained from sources worldwide, and our desire is not to eliminate those originating in the Covered Countries and other CAHRAs, but rather to obtain conflict minerals from sources that do not directly or indirectly finance or benefit armed groups or contribute to human rights abuses. We believe that it is important for us and other companies to support responsible in-region mineral sourcing from the Covered Countries and other CAHRAs and to not negatively affect the economies of such countries.
Products and Supply Chain Description
Mobileye systems that may contain necessary conflict minerals, and which are covered in this Report, include:
| • | our Mobileye EyeQ® System-on-Chips (“SoCs”), such as our EyeQ®2, EyeQ®3, EyeQ®4 and EyeQ®5 SOCs |
| • | our Mobileye SuperVisionTM system |
| • | our aftermarket product portfolio, including Mobileye 8 Connect and Shield+ |
Mobileye sells products that are manufactured for us by other companies and products that include ready-made component parts that we purchase from third parties. Although many of our hardware products contain conflict minerals, we do not purchase ore or unrefined conflict minerals from mines. We are many steps removed in the supply chain from the mining of minerals and are therefore considered a “downstream” purchaser. We purchase materials used in our products from a large network of suppliers; some of those materials contribute necessary conflict minerals to our products. The origin of minerals cannot be determined with any certainty once the ores are smelted, refined, and converted to ingots, bullion, or other derivatives. The smelters and refiners (referred to as “facilities”) are consolidating points for ore and are in the best position in the total supply chain to know the origin of the ores. We rely on our suppliers to assist with our reasonable country of origin inquiry and due diligence efforts, including the identification of smelters and refiners, for the minerals contained in the materials which they supply to us.
Design of Responsible Minerals Program
The design of Mobileye’s responsible minerals program is in conformity with the OECD Guidance specifically as it relates to our position in the minerals supply chain as a “downstream” purchaser. Summarized below are the design components of our responsible minerals program as they relate to the five-step framework from the OECD Guidance.
| 1. | Maintain strong company management systems: |
| • | Responsible Minerals Sourcing Policy: Maintain a supply chain policy for minerals originating from CAHRAs, including conflict minerals originating from the Covered Countries. This policy outlines our commitment to responsible mineral sourcing from CAHRAs, our commitment to exercise due diligence consistent with the OECD Guidance, and expectations that our suppliers have similarly established due diligence programs. Our policy is publicly available and can be found at https://ir.mobileye.com/corporate-governance/governance-overview. |
| • | Internal Responsible Minerals team: Our responsible minerals team monitors our Responsible Minerals Sourcing Policy. We review such efforts with our senior management from our Operations team. |
| • | Supply chain control system: Employ a supply chain system of controls and transparency through due diligence tools such as the Conflict Minerals Reporting Template (CMRT), a regularly updated 3TG sourcing BI report and survey designed by the Responsible Minerals Initiative (RMI) to identify the smelters and refiners that process the necessary conflict minerals contained in our products and the country of origin of those conflict minerals. We employ a database to assess due diligence information and maintain records relating to our responsible minerals program for at least five years, in accordance with the OECD Guidance. |
| • | Supplier engagement: Feature requirements related to responsible minerals sourcing in our standard template for supplier contracts and specifications so that current and future suppliers are obligated to comply with our policies on responsible minerals sourcing, including participation in a supply chain survey and related due diligence activities. We communicate our Responsible Minerals Sourcing Policy and contractual requirements to relevant suppliers annually. |
| • | Company grievance mechanism: Employees, suppliers, and other stakeholders can direct any questions or concerns relating to our responsible minerals program to: conflictminerals@mobileye.com. Employees also may report any concerns through our internal whistleblower reporting mechanism. |
| 2. | Identify and assess risks in our supply chain: |
| • | Identify smelters and refiners in our supply chain: Identify direct suppliers that supply products to Mobileye that may contribute necessary conflict minerals to our products. Conduct an annual supply chain survey requesting those direct suppliers to provide a conflict minerals declaration, using the CMRT, designed to identify the conflict minerals contained in the products they supply to Mobileye, the smelters and refiners that processed those conflict minerals, and the country of origin of those conflict minerals. We evaluate the completeness and accuracy of the suppliers’ survey responses and contact suppliers whose survey response we identified as having contained incomplete or potentially inaccurate information to seek additional clarifying information. |
| • | Identify the scope of the risk assessment: Our risk assessment is designed to identify risks in our supply chain. This includes direct suppliers not meeting our contractual requirements related to conflict minerals as well as smelters and refiners that are not conformant to a responsible mineral assurance program or that we have reason to believe may source conflict minerals from the Covered Countries. We document mineral country of origin information for the smelters and refiners identified by the supply chain survey, as provided from sources including the supply chain survey, responsible mineral assurance programs, and from publicly available sources such as smelter and refiner websites. |
| • | Assess due diligence practices of smelters and refiners: Compare smelters and refiners identified by the supply chain survey against the list of facilities that are conformant to a responsible mineral assurance program such as the RMI’s Responsible Minerals Assurance Program (RMAP), and other RMI cross-recognized, independent third-party audit programs. Information regarding RMAP as well as a list of RMI cross-recognized independent third-party audit programs can be found on the RMI’s website: http://www.responsiblemineralsinitiative.org/minerals-due-diligence/recognized-standards-or-programs/. |
| 3. | Execute a strategy to respond to identified risks: |
| • | Report findings to senior management: Provide progress reports to our Operations team senior management summarizing information gathered during our annual supply chain survey, results from the risk assessment process and status of our risk mitigation efforts. |
| • | Devise and adopt a risk management plan: Maintain a risk management plan that includes due diligence reviews of suppliers, smelters and refiners that may be sourcing or processing conflict minerals from Covered Countries and other CAHRAs which may not be from recycled or scrap sources. Our due diligence measures are significantly based on responsible mineral assurance programs that evaluate the procurement practices of the smelters and refiners that process and provide those conflict minerals to our supply chain. |
| • | Implement a risk management plan: Perform risk mitigation efforts to bring suppliers into conformity with our Responsible Minerals Sourcing Policy or contractual requirements, which efforts may include working with direct suppliers to consider an alternative source for the necessary conflict minerals. |
| • | Ongoing risk monitoring: Monitor and track suppliers, smelters and refiners identified as not meeting the requirements set forth in our Responsible Minerals Sourcing Policy or contractual requirements to determine their progress in meeting those requirements. |
| 4. | Support the development and implementation of independent third-party audits of smelters’ and refiners’ sourcing: |
| • | Support responsible mineral assurance programs that carry out independent third-party audits of smelter and refiner facilities, such as the RMAP, through Intel Corporation’s (“Intel”) membership (as we operate as a subsidiary of Intel) and our own forthcoming membership in the RMI. |
| 5. | Report on supply chain due diligence: |
| • | Publicly communicate our Responsible Minerals Sourcing Policy on our company website at https://ir.mobileye.com/corporate-governance/governance-overview. |
| • | File a Form SD annually with the SEC. This information is publicly available on our company website at https://ir.mobileye.com/financial-information/sec-filings. |
The content of any website referred to in this Report is included for general information only and is not incorporated by reference in this Report.
Description of Reasonable Country of Origin Inquiry Efforts
For 2022, our reasonable country of origin inquiry (RCOI) efforts for conflict minerals included conducting a supply chain survey of our direct suppliers (referred to as “surveyed suppliers”) using the CMRT. The supply chain surveys requested our suppliers to identify the smelters and refiners and countries of origin of the conflict minerals in products they supply to us. We compared the smelters and refiners identified in the surveys against the lists of facilities which are conformant to a responsible mineral assurance program, such as the RMAP or RMI cross-recognized programs. RMAP and RMI cross-recognized programs provided country of origin data for conformant smelters and refiners, including on an aggregate basis in certain cases. We documented country of origin information for the smelter and refiner facilities identified by surveyed suppliers as provided from sources including the supply chain survey and responsible mineral assurance programs.
Results of Reasonable Country of Origin Inquiry Efforts
For 2022, Mobileye conducted a supply chain survey of 39 suppliers that we determined may contribute necessary conflict minerals to our products.
The results of our RCOI as of March 16, 2023 are as follows:
| • | 100% of surveyed suppliers provided a CMRT in response to our supply chain survey request. |
| • | The surveyed suppliers identified 243 operational smelter and refiner facilities which may process the necessary conflict minerals contained in the products provided to us. |
| • | We know or have reason to believe that a portion of the conflict minerals processed by at least 45 of these 243 smelters and refiners may have originated in the Covered Countries and may not be solely from recycled or scrap sources. |
Conclusion Based on Reasonable Country of Origin Inquiry
We have concluded in good faith that during 2022:
| a) | Mobileye manufactured and contracted with others to manufacture products as to which conflict minerals are necessary to the functionality or production of our products. |
| b) | Based on our RCOI, we know or have reason to believe that a portion of the necessary conflict minerals contained in our products originated or may have originated in the Covered Countries and know or have reason to believe that those necessary conflict minerals may not be solely from recycled or scrap sources. |
As a result of the above conclusion and pursuant to the Rule, we undertook due diligence measures on the source and chain of custody of the necessary conflict minerals in our products which we had reason to believe may have originated from the Covered Countries and which may not have come from recycled or scrap sources. There is significant overlap between our RCOI efforts and our due diligence measures performed.
Description of Due Diligence Measures Performed
Below is a description of the measures performed for this reporting period, as of March 16, 2023, to exercise due diligence on the source and chain of custody of the necessary conflict minerals contained in our products:
| • | Conducted a supply chain survey of suppliers which we identified may be supplying Mobileye with products that contain necessary conflict minerals using the CMRT, requesting country of origin information regarding the necessary conflict minerals and identification of smelters and refiners that process such minerals. |
| • | Contacted surveyed suppliers on responses to supply chain surveys that we identified as having contained incomplete or potentially inaccurate information to seek additional clarifying information. |
| • | Received a CMRT from 100% of our surveyed suppliers in response to our supply chain survey request. |
| • | Compared smelters and refiners identified by surveyed suppliers against the list of facilities that are conformant to a responsible mineral assurance program. |
| • | Monitored and tracked surveyed suppliers, and smelters and refiners identified by surveyed suppliers, which we identified as not meeting our Responsible Minerals Sourcing Policy or contractual requirements, to determine their progress in meeting those requirements. |
| • | Performed risk mitigation efforts with surveyed suppliers we identified as not in conformity with our Responsible Minerals Sourcing Policy or contractual requirements by working with them to bring them into compliance. |
Results of our Due Diligence Measures
Inherent Limitations on Due Diligence Measures
As a downstream purchaser of products which contain conflict minerals, our due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the necessary conflict minerals. Our due diligence processes are based on the necessity of seeking data from our direct suppliers and those suppliers seeking similar information within their supply chains to identify the original sources of the necessary conflict minerals. We also rely, to a large extent, on information collected and provided by responsible mineral assurance programs. Such sources of information, as well as any publicly available sources, may yield inaccurate or incomplete information and may be subject to fraud.
Another complicating factor is the unavailability of country of origin and chain of custody information from our suppliers on a continuous, real-time basis. The supply chain of commodities such as conflict minerals is a multi-step process operating more or less on a daily basis, with ore being delivered to smelters and refiners, with smelters and refiners smelting or refining ores into metal containing derivatives such as ingots, with the derivatives being shipped, sold and stored in numerous market locations around the world and with distributors and purchasers holding varying amounts of the derivatives in inventory for use. Since we do not have direct contractual relationships with smelters and refiners, we rely on our direct suppliers and the entire supply chain to gather and provide specific information about the date when the ore is smelted into a derivative and later shipped, stored, sold, and first entered the stream of commerce. We directly seek sourcing data on a periodic basis from our direct suppliers as well as certain smelters and refiners. We seek to use contract provisions requiring the suppliers to promptly update us in the event the sourcing data changes. Our due diligence processes are ongoing throughout the year.
Surveyed Supplier Due Diligence Results
Mobileye evaluated the accuracy and completeness of the responses to our supply chain surveys by our surveyed suppliers. We identified 5 surveyed suppliers whose initial survey response contained incomplete or potentially inaccurate information. We used various methods to identify the incomplete or inaccurate information in the surveyed supplier’s response, including verification checks conducted by third-party software or by members of our internal Responsible Minerals team. When an incomplete or inaccurate response was identified, we contacted the applicable surveyed supplier, identified the incomplete or inaccurate information, and requested that the surveyed supplier correct the incomplete or potentially inaccurate information and provide an updated response. All 5 surveyed suppliers provided an updated CMRT which we determined, using the same evaluation criteria, to be complete and accurate.
Upon receiving a survey response identified to be complete and accurate based on our evaluation criteria, we further evaluated each response for conformity with our Responsible Minerals Sourcing Policy or contractual requirements. These requirements include that our surveyed suppliers must maintain a publicly available conflict minerals sourcing policy, provide a CMRT upon our request, and use smelters and refiners which are either conformant to a responsible mineral assurance program or have begun participating in such a program. We identified surveyed suppliers which were not fully compliant with all applicable requirements and monitored and tracked these suppliers’ progress in meeting the applicable requirements. We performed risk mitigation efforts by contacting each supplier, identifying action items that we requested the supplier complete, and asking the supplier to provide an updated CMRT. Our risk mitigation efforts are specifically related to meeting our Responsible Minerals Sourcing Policy or contractual requirements, with the goal of bringing each surveyed supplier into compliance with such requirements.
As a result of these supplier due diligence activities, Mobileye determined that approximately 95% (37 out of 39) of the surveyed suppliers are, as of March 16, 2023, in compliance with the Responsible Minerals Sourcing Requirements developed by Intel for 2022. As we operate as a subsidiary of Intel, we delegate certain tasks to the Intel group responsible for conflict minerals reporting. After December 31, 2022, nine smelters, reported by 19 of the 39 suppliers surveyed, were removed from the RMAP conformant list. We are working to remove these newly not conformant smelters and have set expectations with all 19 suppliers that they remove these smelters from their supply chain.
Smelter and Refiner Due Diligence Results
As of March 16, 2023, an aggregate of 243 operational smelters and refiners were identified by our surveyed suppliers as facilities that may process the necessary conflict minerals contained in the products these surveyed suppliers provided to Mobileye.
Mobileye conducted due diligence on the smelters and refiners reported during our survey process. Our due diligence activities are dominated by a continual process to determine and monitor whether the identified smelters and refiners are operational and therefore may contribute necessary conflict minerals to our final products, and whether they are conformant to a responsible mineral assurance program or have begun participating in such a program. We sought reliable information on the source and chain of custody of the conflict minerals processed by such facilities, including from publicly available sources, with the goal to determine if any of these facilities processed conflict minerals that may have originated from the Covered Countries and other CAHRAs, and may not be solely from recycled or scrap sources.
If a smelter or refiner in our supply chain was not yet conformant to a responsible mineral assurance program or had not yet begun participating in such a program, Mobileye and other RMI member companies proactively attempted to contact such facilities to request country of origin information for the conflict minerals the facilities processed, as well as to encourage and assist their participation in a responsible mineral assurance program. We monitored and tracked smelters and refiners which we identified as not being conformant to a responsible mineral assurance program or not having begun participating in such a program.
During this reporting year, we identified 33 smelter and refiner facilities reported in our supply chain that were not conformant to a responsible mineral assurance program. These facilities were the focus of our smelter and refiner due diligence activities for this reporting period and, as a result of our activities, we reasonably concluded that as of March 16, 2023:
| • | 10 of these 33 smelter and refiner facilities had later become conformant to a responsible mineral sourcing program. |
| • | Two of these 33 smelter and refiner facilities have begun participating in a responsible mineral assurance program but are not yet conformant. Based on Mobileye’s due diligence, we have no reason to believe these facilities sourced conflict minerals from the Covered Countries. |
| • | The remaining 21 facilities decided not to or were deemed not eligible to continue participating in a responsible mineral assurance program. Of the 21 smelters in our supply chain that were not conformant to a responsible mineral assurance program during 2022, five smelters have been successfully removed from our supply chain. The remaining 16 smelters are reported by two suppliers and Mobileye is working diligently to remove these smelters from our supply chain. |
As a result of our due diligence activities summarized above, we determined the following as of March 16, 2023:
| • | 90% of the 243 smelters and refiners identified by our surveyed suppliers are either conformant to a responsible mineral assurance program or have begun participating in such a program. |
| • | All 45 smelters and refiners which we know or have reason to believe may source conflict minerals from the Covered Countries, which may not be solely from recycled or scrap sources, are conformant to a responsible mineral assurance program. |
| • | We have no reason to believe that any of the 243 smelter and refiner facilities directly or indirectly finance or benefit armed groups in the Covered Countries. |
Below is a summary of the mineral country of origin information collected as of March 16, 2023 as a result of our due diligence activities:
Table 1
| Country | Mineral | |||
| Argentina | Gold | |||
| Australia | Gold | Tantalum | Tin | Tungsten |
| Austria | Tungsten | |||
| Azerbaijan | Gold | |||
| Benin | Gold | |||
| Bolivia | Gold | Tin | Tungsten | |
| Botswana | Gold | |||
| Brazil | Gold | Tantalum | Tin | Tungsten |
| Burkina Faso | Gold | |||
| Burundi** | Tantalum | Tin | Tungsten | |
| Cambodia | Gold | |||
| Canada | Gold | |||
| Chile | Gold | |||
| China | Gold | Tantalum | Tin | Tungsten |
| Colombia | Gold | Tin | ||
| Côte d'Ivoire | Gold | |||
| Democratic Republic of the Congo** | Gold | Tantalum | Tin | Tungsten |
| Dominican Republic | Gold | |||
| Ecuador | Gold | |||
| Egypt | Gold | |||
| Eritrea | Gold | |||
| Ethiopia | Tantalum | |||
| Fiji | Gold | |||
| Finland | Gold | |||
| France | Tin | |||
| French Guiana | Gold | |||
| Georgia | Gold | |||
| Ghana | Gold | |||
| Guatemala | Gold | |||
| Guinea | Gold | |||
| Guyana | Gold | |||
| Honduras | Gold | |||
| India | Gold | |||
| Indonesia | Gold | Tin | ||
| Japan | Gold | |||
| Kazakhstan | Gold | Tungsten | ||
| Kenya | Gold | |||
| Kyrgyzstan | Gold | Tungsten | ||
| Laos | Gold | Tin | ||
| Liberia | Gold | |||
| Malaysia | Gold | Tin | Tungsten | |
| Mali | Gold | |||
| Mauritania | Gold | |||
| Mexico | Gold | Tungsten | ||
| Mongolia | Gold | Tungsten | ||
| Morocco | Gold | |||
| Mozambique | Gold | Tantalum | ||
| Myanmar | Tin | Tungsten | ||
| Namibia | Gold | Tin | ||
| New Zealand | Gold | |||
| Nicaragua | Gold | |||
| Niger | Gold | |||
| Nigeria | Tantalum | Tin | Tungsten | |
| Oman | Gold | |||
| Panama | Gold | |||
| Papua New Guinea | Gold | |||
| Peru | Gold | Tin | Tungsten | |
| Philippines | Gold | |||
| Portugal | Tin | Tungsten | ||
| Russia | Gold | Tin | Tungsten | |
| Rwanda** | Tantalum | Tin | Tungsten | |
| Saudi Arabia | Gold |
| Senegal | Gold | |||
| Serbia | Gold | |||
| Sierra Leone | Tantalum | |||
| South Africa | Gold | |||
| South Korea | Gold | |||
| Spain | Gold | Tantalum | Tin | Tungsten |
| Sudan | Gold | |||
| Suriname | Gold | |||
| Swaziland | Gold | |||
| Sweden | Gold | |||
| Taiwan | Tin | |||
| Tanzania** | Gold | Tin | ||
| Thailand | Tantalum | Tin | Tungsten | |
| Turkey | Gold | |||
| Uganda** | Tungsten | |||
| United Kingdom | Tin | Tungsten | ||
| United States of America | Gold | Tungsten | ||
| Uzbekistan | Gold | |||
| Venezuela | Tin | |||
| Vietnam | Tin | Tungsten | ||
| Zambia** | Gold | |||
| Zimbabwe | Gold | Tantalum | Tungsten |
**Covered Countries
Summary of Smelter and Refiner Status
The charts below summarize, by mineral, the numbers of operational smelter and refiner facilities, identified by our surveyed suppliers, that as of March 16, 2023:
| (i) | are conformant to a responsible mineral assurance program (referred to as “Conformant”); |
| (ii) | have begun participating in a responsible mineral assurance program (referred to as “Active”; as noted above, we have no reason to believe, based on our due diligence, that these facilities process conflict minerals originating from the Covered Countries); or | |
| (iii) | are not conformant* to a responsible mineral assurance program (referred to as “Non Conformant”; as noted above, we have no reason to believe, based on our due diligence, that these facilities process conflict minerals originating from the Covered Countries). |
Status of Identified Smelters and Refiners
*Included in “Not Conformant” are the 9 smelters which changed status between January 1, 2023, and March 16, 2023.
The table below (Table 2) lists the facilities which, to the extent known, processed the necessary conflict minerals in our products based on responses received from our surveyed suppliers as of March 16, 2023. Mobileye conducts no direct transactions and has no contractual relationship with these smelter and refiner facilities nor their sources of ore.
Table 2
| Metal | Smelter Name† | Country† |
| Gold | 8853 S.p.A. | ITALY |
| 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 | C.I Metales Procesados Industriales SAS** | COLOMBIA |
| Gold | CCR Refinery - Glencore Canada Corporation* | CANADA |
| Gold | Cendres + Metaux S.A. | SWITZERLAND |
| Gold | Chimet S.p.A.* | ITALY |
| Gold | Chugai Mining* | JAPAN |
| Gold | Dowa* | JAPAN |
| Gold | DSC (Do Sung Corporation)* | SOUTH KOREA |
| 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 | Emirates Gold DMCC* | UNITED ARAB EMIRATES |
| Gold | Geib Refining Corporation* | UNITED STATES OF AMERICA |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd.** | INDIA |
| 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 | JSC Novosibirsk Refinery | RUSSIA |
| Gold | JSC Uralelectromed | RUSSIA |
| 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.* | SOUTH KOREA |
| Gold | L'Orfebre S.A.* | ANDORRA |
| Gold | LS-NIKKO Copper Inc.* | SOUTH KOREA |
| Gold | LT Metal Ltd.* | SOUTH KOREA |
| Gold | Marsam Metals | BRAZIL |
| 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 | Moscow Special Alloys Processing Plant | RUSSIA |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S.* | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat* | UZBEKISTAN |
| Gold | NH Recytech Company* | SOUTH KOREA |
| 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) | RUSSIA |
| Gold | Planta Recuperadora de Metales SpA* | CHILE |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIA |
| 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 | Samduck Precious Metals | SOUTH KOREA |
| 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 | Singway Technology Co., Ltd. | TAIWAN |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIA |
| Gold | Solar Applied Materials Technology Corp.* | TAIWAN |
| Gold | Sumitomo Metal Mining Co., Ltd.* | JAPAN |
| Gold | SungEel HiMetal Co., Ltd.* | SOUTH KOREA |
| 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* | SOUTH KOREA |
| 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 | 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 | AMG Brasil* | BRAZIL |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | CHINA |
| 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 | 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 | QuantumClean* | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda.* | BRAZIL |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd.* | CHINA |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIA |
| 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 Synergies* | SPAIN |
| Tin | CV Venus Inti Perkasa* | INDONESIA |
| Tin | Dowa* | JAPAN |
| Tin | EM Vinto* | BOLIVIA |
| Tin | Estanho de Rondonia S.A.* | BRAZIL |
| Tin | Fabrica Auricchio Industria e Comercio Ltda.* | BRAZIL |
| Tin | Fenix Metals* | POLAND |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA |
| Tin | Guangdong Hanhe Non-Ferrous Metal 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 | Melt Metais e Ligas S.A. | BRAZIL |
| Tin | Metallic Resources, Inc.* | UNITED STATES OF AMERICA |
| 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 Metalurgicas 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 Babel Surya Alam Lestari* | INDONESIA |
| Tin | PT Bangka Serumpun* | 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 Prima Timah Utama* | INDONESIA |
| Tin | PT Putera Sarana Shakti (PT PSS)* | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa* | 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 | Resind Industria e Comercio Ltda.* | BRAZIL |
| Tin | Rui Da Hung* | TAIWAN |
| 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 | ACL Metais Eireli | BRAZIL |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | BRAZIL |
| 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 Ganmin RareMetal Co., Ltd.* | CHINA |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd.* | CHINA |
| Tungsten | Ganzhou Haichuang 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 |
| 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 Jintai New Material Co., Ltd.* | CHINA |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch* | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIA |
| 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 | JSC "Kirovgrad Hard Alloys Plant" | RUSSIA |
| Tungsten | Kennametal Fallon* | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville* | UNITED STATES OF AMERICA |
| Tungsten | Lianyou Metals Co., Ltd.* | TAIWAN |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | CHINA |
| Tungsten | Masan High-Tech Materials* | VIETNAM |
| Tungsten | Moliren Ltd. | RUSSIA |
| Tungsten | Niagara Refining LLC* | UNITED STATES OF AMERICA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc.* | PHILIPPINES |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG* | GERMANY |
| Tungsten | Unecha Refractory metals plant | RUSSIA |
| Tungsten | Wolfram Bergbau und Hutten AG* | AUSTRIA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd.* | CHINA |
| † | Smelter and refiner facility names and locations as reported by the RMI as of March 16, 2023. |
| * | Denotes smelters and refiners which are conformant to a responsible mineral assurance program as of March 16, 2023. |
| ** | Denotes smelters and refiners which are participating in a responsible mineral assurance program as of March 16, 2023. |
Conclusion and Future Due Diligence Measures
The facilities reported in Table 2 processed the necessary conflict minerals in our products based on responses received from 100% of our surveyed suppliers as of March 16, 2023. As of March 16, 2023, 90% of the reported smelter and refiner facilities are conformant or are participating in a responsible mineral assurance program. All smelters and refiners which we know or have reason to believe may source conflict minerals from the Covered Countries which may not be solely from recycled or scrap sources are conformant to a responsible mineral assurance program as of March 16, 2023. We have no reason to believe that any of the reported smelter and refiner facilities directly or indirectly finance or benefit armed groups in the Covered Countries. We are continuing to engage in the activities described above in “Design of Responsible Minerals Program” and we are continuing to follow up with suppliers that are not meeting our requirements as well as contacting smelters and refiners that are not yet conformant to a responsible mineral assurance program. We are encouraging and assisting such smelters and refiners to become conformant to a responsible mineral assurance program, thus supporting our efforts to build ethical and socially responsible supply chains for our company.
Our efforts to determine the mine or location of origin of the necessary conflict minerals in all our products with the greatest possible specificity consisted of the due diligence measures described in this Report. In particular, we relied on the information made available by responsible mineral assurance programs for the smelters and refiners in our supply chain because such programs review and audit whether sufficient evidence exists regarding the mine and/or location of origin of the conflict minerals that the audited smelter and refiner facilities have processed. We also sought source and chain of custody information directly from smelters and refiners and from publicly available sources and, if we determined such information to be reliable, we used the information to make reasonable conclusions on the source and chain of custody of the conflict minerals processed by facilities which were not conformant to or participating in a responsible mineral assurance program.