UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
SPECIALIZED DISCLOSURE REPORT
Zebra Technologies Corporation
(Exact name of the registrant as specified in its charter)
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| Delaware | | 000-19406 | | 36-2675536 |
(State or other jurisdiction
of incorporation or organization) | | (Commission
File Number) | | (IRS Employer
Identification No.) |
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| 3 Overlook Point, Lincolnshire, Illinois | | 60069 |
| (Address of principal executive offices) | | (Zip code) |
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| Cristen Kogl | | 847-793-5512 |
(Name and telephone number, including area code, of the
person to contact in connection with this report.) |
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
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| ☒ | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1, 2023, to December 31, 2023. |
Introduction
Effective for the year ending December 31, 2023, Zebra Technologies Corporation (“Zebra”) must disclose whether any conflict minerals necessary to the functionality or production of a product manufactured by Zebra (or contracted by Zebra to be manufactured) originated in the Democratic Republic of the Congo (“DRC”) or a country adjoining the DRC [Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia, together the “Covered Countries”], or whether the conflict minerals are from recycled or scrap sources. The disclosure requirement arose from Congress’s determination that trade in conflict minerals in a DRC country is financing conflict in those areas, contributing to a humanitarian crisis.
The term “conflict mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives; or (B) any other mineral or its derivatives determined by the Secretary of State to be financing conflict in the DRC or Covered Countries (“Conflict Minerals”).
Section 1 – Conflict Minerals Disclosures
Item 1.01 Conflict Minerals Disclosure and Report
Conflict Minerals Disclosure
In accordance with Rule 13p-1 under the Securities Exchange Act of 1934 (‘Rule 13p-1”), Zebra Technologies Corporation (“Zebra”) has filed this Specialized Disclosure Form (“Form SD”) and the associated Exhibit 1.01 Conflict Minerals Report for the reporting period January 1, 2023, to December 31, 2023 and is publicly available on Zebra’s website under “Company Information”/“Compliance”/“Products and Materials Compliance” found on Zebra’s website at https://www.zebra.com/us/en/about-zebra/company-information/compliance/products-and-materials-compliance.html.
After conducting a reasonable country of origin inquiry and our supply chain due diligence inquiry, Zebra has been unable to determine that certain of its conflict minerals did not originate in the Covered Countries or come from recycled or scrap sources, or that such conflict minerals did not directly or indirectly finance or benefit armed groups in the Covered Countries.
Item 1.02 – Exhibits
The Zebra Technologies Corporation Conflict Minerals Report is attached to this report as Exhibit 1.01.
Section 2 – Exhibits
Item 2.01 Exhibits
Exhibit 1.01 – Conflict Minerals Report of Zebra Technologies Corporation for the period January 1, 2023, to December 31, 2023, as required by Items 1.01 and 1.02 of this Form SD.
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SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
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| | | | ZEBRA TECHNOLOGIES CORPORATION |
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| Dated: May 29, 2024 | | | | By: | | /s/ Cristen Kogl |
| | | | | | Name: Cristen Kogl |
| | | | | | Title: Chief Legal Officer,
General Counsel and Corporate Secretary |
EXHIBIT INDEX
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Exhibit
Number | | Description of Exhibits | | |
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| 1.01 | | Conflict Minerals Report of Zebra Technologies Corporation for the period January 1, 2023, to December 31, 2023. | | |
CONFLICT MINERALS REPORT OF
ZEBRA TECHNOLOGIES CORPORATION
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FOR THE REPORTING PERIOD FROM JANUARY 1 TO DECEMBER 31, 2023 |
I.Introduction
In accordance in all material respects with Rule 13p-1 (“Rule 13p-1”) under the Securities Exchange Act of 1934 (the “Act”), Zebra undertook efforts to determine whether the necessary Conflict Minerals in our products were or were not “DRC conflict free.” This is the Conflict Minerals Report of Zebra Technologies Corporation (“Zebra,” the “Company,” “our” or “we”) for calendar year 2023 (excepting Conflict Minerals1 that, prior to January 31, 2023, were located outside of the supply chain) in accordance in all material respects with Rule 13p-1 (the “Report”). Numerous terms in this Report are defined in Rule 13p-1 of the Act and Specialized Disclosure Form (“Form SD”) and the reader is referred to those sources, as well as, to Release No. 34-67716 (August 22, 2012) of the Act (the “Adopting Release”) for such definitions.
The statements below are based on the due diligence activities performed to date and in good faith by Zebra and are based on the information available at the time of this filing. There are factors that could affect the accuracy of these statements. These factors include, but are not limited to, incomplete supplier data or available smelter data, errors or omissions by suppliers or smelters in responding to information requests, incomplete information from industry or other third-party sources, and continuing guidance regarding the SEC final rules.
II. Zebra’s Manufacturing and Outsourcing Description
We are a global leader in the Automatic Identification and Data Capture (“AIDC”) industry. The AIDC market consists of mobile computing, data capture, radio frequency identification devices (“RFID”), barcode printing, and other workflow automation products and services. The Company’s solutions are proven to help our customers and end-users digitize and automate their workflows to achieve their critical business objectives, including improved productivity and operational efficiency, optimized regulatory compliance, and better customer experiences.
We design, manufacture, and sell a broad range of AIDC products, including: mobile computers, barcode scanners and imagers, RFID readers, specialty printers for barcode labeling and personal identification, real-time location systems (“RTLS”), related accessories and supplies, such as labels and other consumables, and related software applications. We also provide machine vision and robotics automation solutions; a full range of services, including maintenance, technical support, repair, managed and professional services; as well as cloud-based software subscriptions. End-users of our products, solutions and services include those in the retail and e-commerce, manufacturing, transportation and logistics, healthcare, public sector, and other industries. We operate in 122 facilities with approximately 9,750 employees worldwide. We provide our products, solutions and services globally through a direct sales force and extensive network of over 10,000 channel partners, operating in approximately 185 countries.
Final assembly of our hardware products is performed by third-parties, including electronics manufacturing services companies (“EMSs”) and joint design manufacturers (“JDMs”). Our products are currently produced in facilities primarily located in the Asia-Pacific region, including China, Taiwan, Vietnam, and Malaysia, as well as Mexico and Brazil. The EMSs and JDMs produce our products to our design specifications. We maintain control over portions of the supply chain, including supplier selection and price negotiations for key components. The manufacturers generally purchase all the components and subassemblies used in the production of our products. Our
1 The term “Conflict Mineral” is defined in Section 1502(e)(4) of the Act as (A) columbite-tantalite, also known as coltan (the metal ore from which tantalum is extracted); cassiterite (the metal ore from which tin is extracted); gold; wolframite (the metal ore from which tungsten is extracted); or their derivatives (collectively referred to as “3TG”).
products are shipped to regional distribution centers, operated by third party logistics providers or the Company. A portion of products are reconfigured at the distribution centers through firmware downloads, packaging, and customer specific customization before they are shipped to customers. In addition, certain products are manufactured in accordance with procurement regulations and various international trade agreements and remain eligible for sale to the U.S. government.
Production facilities for our supplies products are located in the U.S. and Western Europe. We also supplement our in-house supplies production capabilities with third-party manufacturers, principally located in Asia-Pacific.
III.Zebra’s Product Description
Acquisitions
Matrox: On June 3, 2022, the Company acquired Matrox Electronic Systems Ltd. (“Matrox”). Matrox is a leading provider of advanced machine vision components and software serving multiple end-markets. Through its acquisition, the Company significantly expands machine vision products and software offerings.
Antuit: On October 7, 2021, the Company acquired Antuit Holdings Pte. Ltd. (“Antuit”). Antuit is a provider of demand-sensing and pricing optimization software solutions for retail and consumer products companies. Through this acquisition, the Company expands its portfolio of software solution offerings to customers in these industries by combining Antuit’s platform with its existing software solutions and EVM products.
Fetch: On August 9, 2021, the Company acquired Fetch Robotics, Inc. (“Fetch”). Fetch is a provider of autonomous mobile robot solutions for customers who operate in the manufacturing, distribution, and fulfillment industries, enabling customers to optimize workflows through robotic automation. Through this acquisition, the Company intends to expand its automation solution offerings within these industries.
Adaptive Vision: On May 17, 2021, the Company acquired Adaptive Vision Sp. z o.o. (“Adaptive Vision”). Adaptive Vision is a provider of graphical machine vision software with applications in the manufacturing industry, as well as a provider of libraries and other offerings for machine vision developers.
Reflexis: On September 1, 2020, the Company acquired Reflexis Systems, Inc. (“Reflexis”). Reflexis is a provider of task and workforce management, execution, and communication software solutions for customers in the retail, food service, hospitality, and banking industries. Through this acquisition, the Company intends to enhance its solution offerings to customers in those industries by combining Reflexis’ platform with its existing software solutions and EVM products.
Cortexica: On November 5, 2019, the Company acquired Cortexica Vision Systems Limited (“Cortexica”). Cortexica is a provider of computer vision-based artificial intelligence solutions primarily serving the retail industry.
Profitect: On May 31, 2019, the Company acquired Profitect, Inc. (“Profitect”). Profitect is a provider of prescriptive analytics software primarily serving the retail industry. Through this acquisition, the Company enhanced its existing software solutions within the retail industry by combining Profitect’s platform with its existing software solutions and EVM products.
Temptime: On February 21, 2019, the Company acquired Temptime Corporation (“Temptime”). Temptime is a developer and manufacturer of temperature-monitoring labels and devices. Through this acquisition, the Company
expanded its product offerings within the healthcare industry, with possible future applications in other industries involving temperature-sensitive products.
Xplore: On August 14, 2018, the Company acquired all outstanding equity interests of Xplore Technologies Corporation (“Xplore”). The Xplore business designs, integrates, markets and sells rugged tablets that are primarily used by industrial, government, and field service organizations. The acquisition of Xplore is intended to expand the Company’s portfolio of mobile computing devices to serve a wider range of customers.
Enterprise Business: In October of 2014, Zebra acquired the Enterprise business (“Enterprise”) from Motorola Solutions, Inc. (“MSI”), excluding its iDEN, or Integrated Digital Enhanced Network Business. The Enterprise products include rugged and enterprise-grade mobile computers, barcode scanners and RFID readers, WLAN solutions, and accessories, software and services that are associated with these products.
Operations and Technologies
Our operations consist of two reportable segments that provide complementary offerings to our customers: Asset Intelligence & Tracking (“AIT”), which includes barcode and card printing, RFID and RTLS offerings, supplies, and services; and Enterprise Visibility & Mobility (“EVM”), which includes mobile computing, data capture, fixed industrial scanning and machine vision, services and workflow optimization solutions.
Asset Intelligence & Tracking
Barcode and Card Printing: We design, manufacture, and sell printers, which produce high-quality labels, wristbands, tickets, receipts, and plastic cards on demand. Our customers use our printers in a wide range of applications, including routing and tracking, patient safety, transaction processing, personal identification, product authentication, ticketing and receipts. These applications require high levels of data accuracy, speed, and reliability.
Our printers use thermal printing technology, which creates images by heating certain pixels of an electrical printhead to selectively image a ribbon or heat-sensitive substrate. Our printers integrate company-designed mechanisms, electrical systems, and firmware that supports serial, parallel, Ethernet, USB, Bluetooth, or 802.11 wireless communications with appropriate security protocols. Enclosures of metal or high-impact plastic help ensure durability of our printers. Printing instructions can be received as a proprietary language such as Zebra Programming Language II, as a print driver-provided image, or as user-defined Extensible Markup Language. These features make our printers easy to integrate into most computer systems.
We also provide dye-sublimination thermal card printers that produce high quality images and are used for secure, reliable personal identification (e.g. state identification cards, drivers’ licenses, and healthcare identification cards), access control (e.g. employee or student building access), and financial transactions (e.g. credit, debit and ATM cards). Additionally, we provide RFID printers that encode data into passive RFID transponders embedded in a label or card. We offer a wide range of accessories and options for our printers, including carrying cases, vehicle mounts and battery chargers.
RFID and RTLS Offerings: We provide a range of hardware and software options for capturing location data to satisfy a large variety of requirements for range, accuracy, and precision. Our active and passive RFID products include fixed readers, RFID enabled mobile computers, and RFID sleds that utilize passive ultra-high frequency to provide high-speed, non-line of sight data capture from hundreds or thousands of RFID tags in near real-time. Using the Electronic Product Code (“EPC”) standard, end-users across multiple industries use our RFID technology to track high-value assets, monitor shipments, and drive increased retail sales through improved inventory accuracy.
Our location solutions offerings include a range of RTLS and services that generate precise, on-demand information about the physical location and status of high-valued assets, equipment, and people. These solutions incorporate active and passive RFID technologies, beacons, and other tracking technologies to enable users to locate, track, manage, and optimize the utilization of enterprise assets and personnel. We provide substantially all elements of the location solution, including tags, sensors, exciters, middleware software, and application software.
Supplies: We produce and sell stock and customized thermal labels, receipts, ribbons, plastic cards, and RFID tags suitable for use with our printers, as well as wristbands for use in laser printers. We support our printing products, resellers, and end-users with an extensive line of superior quality, high-performance supplies optimized to a particular end-user’s needs, such as chemical or abrasion resistance, extreme temperature environments, exceptional image quality, or long life. We promote the use of supplies with our printing equipment. Our supplies business also includes temperature-monitoring labels primarily used in vaccine distribution, which incorporate chemical indicators designed to change color upon exceeding predefined time and/or temperature thresholds.
Services: We provide a full range of maintenance, technical support, and repair services. We also provide managed and professional services, including those which help customers manage their devices and related software applications. Our offerings include cloud-based subscriptions and multiple service levels. They are typically contracted through multi-year service agreements. We provide our services directly and through our global network of partners.
Enterprise Visibility & Mobility
Mobile Computing: We design, manufacture, and sell rugged and enterprise-grade mobile computing products and accessories in a variety of specialized form factors and designs to meet a wide array of enterprise applications. Purpose-built devices ensure reliable operations for targeted use cases, surviving years of rough handling and harsh environments. Industrial applications include inventory management in warehouses and distribution centers; field mobility applications include field service, post and parcel, and direct store delivery; and retail and customer facing applications include e-commerce, omnichannel, mobile point of sale, inventory look-up, staff collaboration, and analytics. Our mobile computing products primarily incorporate the Android™ operating system and support local-area and wide-area voice and data communications. Our products are also offered with software tools and services that enable secure data transmission while also supporting application development, device configuration, and field support to facilitate seamless, rapid deployment and maximum customer return on investment. Our products often incorporate barcode scanning, global position system and RFID features, and other sensory capabilities. Additionally, specialized features, such as advanced data capture technologies, data analytics technologies, voice and video collaboration tools, and advanced battery technologies, enable our customers to work more efficiently and better serve their own customers.
Data Capture, Fixed Industrial Scanning, and Machine Vision: We design, manufacture, and sell barcode scanners, industrial machine vision cameras, and fixed industrial scanners. Our portfolio of scanners includes laser scanning and imager products in a variety of form factors, including fixed, handheld, and embedded original equipment manufacturer (“OEM”) modules. Our scanners incorporate a range of technologies including area imagers, linear imagers, and lasers, as well as read linear and two-dimensional barcodes. They are used in a broad range of applications, ranging from supermarket checkouts to industrial warehouse optimization to patient management in hospitals. The design of these products reflects the diverse needs of these markets, with different ergonomics, multiple communication protocols, and varying levels of ruggedness. In 2021 we introduced fixed industrial scanning and machine vision solutions, and in 2022, we significantly expanded our machine vision solutions through the acquisition of Matrox Imaging. Our fixed industrial scanning products automatically track and trace items that
move from production through distribution. Our industrial machine vision platform-independent software, software development kits, smart cameras, vision controllers, frame grabbers, input/output cards, and 3D sensors capture, inspect, assess, and record data from industrial vision systems in factory automation, semiconductor inspection, pharmaceutical packaging, food & beverage, among other use cases. We also provide related software and accessories for these products.
Services: We provide a full range of maintenance, technical support, and repair services. We also provide managed and professional services that, among other things, help customers design, test, and deploy our solutions as well as manage their mobility devices, software applications and workflows. Our offerings include cloud-based subscriptions with multiple service levels, which are typically contracted through multi-year service agreements. We provide our services directly and through our global network of partners.
Workflow optimization solutions: We provide a portfolio of solutions that help our customers improve the agility and productivity of key operational workflows by analyzing and acting on data in real time. Our primary focus is on frontline workers in Zebra’s core customer segments, including retail, transportation and logistics, warehouse and distribution, and healthcare. Our workflow optimization solutions include:
•Software-based solutions, which include workforce management, workflow execution and task management, demand-sensing, price optimization, prescriptive analytics, as well as communication and collaboration-based solutions. These solutions are typically delivered through cloud-based software subscriptions and leverage big data, artificial intelligence, and mobile and web applications to provide customers with real-time visibility and actionable insights about their business. By analyzing labor, inventory, transactional and real-time situational data, these solutions are able to forecast demand, prescribe actions, schedule workers, and enhance collaboration. Our software-based solutions are available with multiple service levels, and are often contracted through multi-year service agreements;
•Retail solutions, which include a range of physical inventory management solutions, including solutions for full store physical inventories, cycle counts, and analytics; and
•Robotic automation solutions, which include software-powered autonomous robots that enable customers to orchestrate workflows alongside frontline workers, improving productivity and operational efficiency. Our robotic automation solutions are available in a variety of form factors to accommodate many use cases.
IV.Zebra’s Due Diligence Process
Zebra’s Conflict Minerals Report relates to the diligence process undertaken for Zebra products that were manufactured, or contracted to be manufactured on behalf of Zebra, during calendar 2023. Zebra’s process to exercise due diligence and to determine country of origin was based on the following approach:
1)Identification of Zebra products that contain 3TG metals necessary to the functionality or production of said products;
2)Collection and review of supplier conflict minerals reports for completeness and accuracy;
3)Evaluation and verification of the collected data, including smelter information reported from each source; and
4)Review and report results.
Zebra supports an industry initiative which audits the due diligence activities of the smelters and refiners: that industry initiative is the Responsible Minerals Initiative (the “RMI”), which was formerly known as the Conflict-Free Sourcing Initiative (“CFSI”), organized and operating under the auspices of the Responsible Business Alliance (“RBA”) [formerly known as Electronic Industry Citizenship Coalition (“EICC”) and Global e-Sustainability Initiative (“GeSI”)].
The RMI provides companies with tools and resources to make sourcing decisions that improve regulatory compliance and support responsible sourcing from conflict-affected and high-risk areas. The RMI designed and manages the Responsible Minerals Assurance Process (“RMAP”), formerly the Conflict-Free Smelter Program (“CFSP”), to identify the smelters that process 3TG and to independently audit those smelters to certify those whose operations are conformant with the RMI RMAP audit protocol. The data on which we relied for certain statements in our Conflict Minerals Report was obtained through our membership in RMI using the Reasonable Country of Origin Inquiry report for members - Zebra’s RMI member code for 2023 reporting is ZKXB.
The Zebra collection and diligence process utilized the RMI Conflict Minerals Reporting Template (“CMRT”), which is the standardized reporting tool that facilitates the collection and transfer of information through the supply chain regarding mineral country of origin and the smelters and refiners being utilized. Throughout the data collection process for the 2023 reporting year, Zebra continued to utilize the latest version of the CMRT during our due diligence process, CMRT v6.31, published in May of 2023.
The following steps were taken as part of our overall risk assessment process:
•Identify in-scope products: Zebra utilized a cross-functional team of employees to review the categories of products that we sell to determine the products that are in-scope as described in the Adopting Release. Through this analysis, Zebra Procurement identified 192 active suppliers comprising approximately 99.02% of Zebra’s 2023 spend on component parts supplied and used in the manufacture of Zebra products during 2023.
•Conduct Reasonable Country of Origin Inquiry (“RCOI”): Zebra procures its components from a variety of suppliers around the world, and we rely on our direct suppliers to provide information on the source of the 3TG materials contained in components and products supplied to Zebra - including sources of 3TG that are supplied to them from upstream suppliers. As part of the RCOI, Zebra utilized the industry developed CMRT survey tool, which requests suppliers to identify the 3TG in their products; report information about the sources of the 3TG; and provide other information that is used to assess whether they are potentially sourcing from smelters or refiners known to directly or indirectly support conflict in the Covered Countries.
We conducted our data collection by approaching suppliers directly to request completion of the currently available CMRT and asked them to submit the data to us by the 2023 year-end. In total, Zebra collected and reviewed 3TG information for 182 unique suppliers representing 99% of our total spend during 2023 [ten (10) suppliers failed to respond to Zebra’s direct request]. We have reviewed CMRT declarations for completeness and consistency and used the RMI smelter/refinery database tool (RBA SOR Master formerly known as CM Master), updated monthly, for smelter validation. Additionally, we used an independent research of public domain information to determine non-certified smelters’ potential risk.
•Identify smelters/refiners: For 2023, Zebra’s suppliers identified 348 smelters or refiners in their CMRT survey responses. In finalizing our data analysis, we relied upon the RMI RCOI table for RMI members-only data for certified conflict-free smelters or refiners; RMI due diligence library; RBA SOR Master, which was updated monthly; and our independent research of NGO sites and publicly available information for smelter validation. We evaluated the reported smelters and refiners against the list of smelters and refiners listed on the RMI’s Standard Smelter List as having valid smelting or refining operations, and against the list of smelter facilities designated as “conformant” by the RMI’s independent third-party smelter audit program or the equivalent certifying bodies such as London Bullion Market Association (the “LBMA”) and the Responsible Jewelry Council (the “RJC”); and based upon these reviews, 244 or 70.1% of reported smelters or refiners are either certified as conformant or are engaged in the RMI RMAP, and a total of 104 smelters or refiners and recyclers are not considered “conformant.”
Based on the information received from our suppliers through Zebra’s diligence process, some information provided by our suppliers was unverifiable or incomplete and as such, we are unable to verify with certainty the source and chain of custody of all 3TGs used in our products. Please see the facilities listed in Table 1 to this Report for the list
of facilities that have been reported as the source of 3TGs used in the manufacturing of Zebra products during the 2023 reporting year.
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| We have consolidated the results of Zebra’s due diligence on the 3TG used in Zebra’s in-scope products, and said results are summarized in the below table: | |
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| Smelters* | Tantalum | Tin | Tungsten | Gold | Totals |
| Number of smelters reported | 39 | 88 | 48 | 173 | 348 |
Number of smelters listed as conformant (passed Audit by RMI, LBMA, RJC) | 36 | 72 | 33 |
103 |
244 |
* The table represents those smelters and refiners disclosed by our suppliers that are listed on the RMI’s Standard Smelter List as having valid smelting or refining operations in 2023, and those which are listed as being certified as conformant or engaged in RMAP, based upon the information available on the RMI’s website (http://www.responsiblemineralsinitiative.org/ ).
V. Conflict Minerals Report
After conducting a reasonable country of origin inquiry and our supply chain due diligence assessment, Zebra has been unable to determine whether sourcing of 3TG metals used in its products directly or indirectly contributed to armed conflicts in the Covered Countries. Accordingly, this Conflict Minerals Report has been filed with the SEC and is publicly available on Zebra’s website under “AboutZebra” / “Compliance” / “Conflict Minerals Disclosure Report” found on Zebra’s website at https://www.zebra.com/us/en/about-zebra/company-information/compliance/products-and-materials-compliance.html.
•Product Determination
As a result of Zebra’s diligence efforts, we have concluded that as of December 31, 2023, our products are not considered to be “DRC conflict free” (as defined). Zebra is making this determination because we have concluded in good faith that during 2023, we do not have sufficient information from suppliers or other sources to conclude at this time whether the necessary conflict minerals for in-scope products are in fact DRC conflict free.
VI. Steps to Improve Due Diligence
Zebra expects that the amount of information globally on the traceability and sourcing of Conflict Minerals will continue to increase and this will enable Zebra to continue to make informed decisions regarding its supply chain. Zebra will continue to evaluate its diligence process and work to improve the diligence conducted to help reduce the risk that our necessary Conflict Minerals do not directly or indirectly benefit armed groups in the DRC and Covered Countries.
Zebra’s diligence of its suppliers remains ongoing, and we continue to work to collect accurate and complete responses from our suppliers through the continued use of tools like the Conflict Minerals Reporting Template. Zebra will also review and test its supplier responses against the information collected via independent conflict free smelter validation programs such as the Responsible Minerals Initiative.
Finally, Zebra will continue to monitor changes in circumstances that may impact our determination under the Act.
VII. Independent Private Sector Audit
As Zebra has not described any of its products as “DRC conflict free” in this Report, and pursuant to the Act, an audit is not required for calendar year 2023.
Table 1
SMELTERS CURRENTLY CERTIFIED AS CONFORMANT BY RMI OR EQUIVALENT ORGANIZATION (LBMA, RJC)
This list contains certified conformant smelters reported by Zebra suppliers using 2023 RMI Conflict Minerals Reporting Template v6.31.
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| Metal | Smelter Name | Smelter ID | Country Location |
| Gold | 8853 S.p.A. | CID002763 | ITALY |
| Gold | Abington Reldan Metals, LLC | CID002708 | UNITED STATES OF AMERICA |
| Gold | Advanced Chemical Company | CID000015 | UNITED STATES OF AMERICA |
| Gold | Agosi AG | CID000035 | GERMANY |
| Gold | Aida Chemical Industries Co., Ltd. | CID000019 | JAPAN |
| Gold | Al Etihad Gold Refinery DMCC | CID002560 | UNITED ARAB EMIRATES |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | CID000041 | UZBEKISTAN |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | CID000058 | BRAZIL |
| Gold | Argor-Heraeus S.A. | CID000077 | SWITZERLAND |
| Gold | Asahi Pretec Corp. | CID000082 | JAPAN |
| Gold | Asahi Refining Canada Ltd. | CID000924 | CANADA |
| Gold | Asahi Refining USA Inc. | CID000920 | UNITED STATES OF AMERICA |
| Gold | Asaka Riken Co., Ltd. | CID000090 | JAPAN |
| Gold | Aurubis AG | CID000113 | GERMANY |
| Gold | Bangalore Refinery | CID002863 | INDIA |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | CID000128 | PHILIPPINES |
| Gold | Boliden Ronnskar | CID000157 | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | CID000176 | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CID000185 | CANADA |
| Gold | Cendres + Metaux S.A. | CID000189 | SWITZERLAND |
| Gold | Chimet S.p.A. | CID000233 | ITALY |
| Gold | Chugai Mining | CID000264 | JAPAN |
| Gold | Dowa | CID000401 | JAPAN |
| Gold | DSC (Do Sung Corporation) | CID000359 | KOREA, REPUBLIC OF |
| Gold | Eco-System Recycling Co., Ltd. East Plant | CID000425 | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. North Plant | CID003424 | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. West Plant | CID003425 | JAPAN |
| Gold | Gold by Gold Colombia | CID003641 | COLOMBIA |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CID002243 | CHINA |
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| Metal | Smelter Name | Smelter ID | Country Location |
| Gold | Heimerle + Meule GmbH | CID000694 | GERMANY |
| Gold | Heraeus Germany GmbH Co. KG | CID000711 | GERMANY |
| Gold | Heraeus Metals Hong Kong Ltd. | CID000707 | CHINA |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CID000801 | CHINA |
| Gold | Ishifuku Metal Industry Co., Ltd. | CID000807 | JAPAN |
| Gold | Istanbul Gold Refinery | CID000814 | TURKEY |
| Gold | Italpreziosi | CID002765 | ITALY |
| Gold | Japan Mint | CID000823 | JAPAN |
| Gold | Jiangxi Copper Co., Ltd. | CID000855 | CHINA |
| Gold | JX Nippon Mining & Metals Co., Ltd. | CID000937 | JAPAN |
| Gold | Kazzinc | CID000957 | KAZAKHSTAN |
| Gold | Kennecott Utah Copper LLC | CID000969 | UNITED STATES OF AMERICA |
| Gold | KGHM Polska Miedz Spolka Akcyjna | CID002511 | POLAND |
| Gold | Kojima Chemicals Co., Ltd. | CID000981 | JAPAN |
| Gold | Korea Zinc Co., Ltd. | CID002605 | KOREA, REPUBLIC OF |
| Gold | L'Orfebre S.A. | CID002762 | ANDORRA |
| Gold | LS MnM Inc. | CID001078 | KOREA, REPUBLIC OF |
| Gold | LT Metal Ltd. | CID000689 | KOREA, REPUBLIC OF |
| Gold | Materion | CID001113 | UNITED STATES OF AMERICA |
| Gold | Matsuda Sangyo Co., Ltd. | CID001119 | JAPAN |
| Gold | Metal Concentrators SA (Pty) Ltd. | CID003575 | SOUTH AFRICA |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CID001149 | CHINA |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | CID001152 | SINGAPORE |
| Gold | Metalor Technologies (Suzhou) Ltd. | CID001147 | CHINA |
| Gold | Metalor Technologies S.A. | CID001153 | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | CID001157 | UNITED STATES OF AMERICA |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | CID001161 | MEXICO |
| Gold | Mitsubishi Materials Corporation | CID001188 | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | CID001193 | JAPAN |
| Gold | MKS PAMP SA | CID001352 | SWITZERLAND |
| Gold | MMTC-PAMP India Pvt., Ltd. | CID002509 | INDIA |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | CID001220 | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | CID001236 | UZBEKISTAN |
| Gold | NH Recytech Company | CID003189 | KOREA, REPUBLIC OF |
| Gold | Nihon Material Co., Ltd. | CID001259 | JAPAN |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | CID002779 | AUSTRIA |
| Gold | Ohura Precious Metal Industry Co., Ltd. | CID001325 | JAPAN |
| Gold | Planta Recuperadora de Metales SpA | CID002919 | CHILE |
| Gold | PT Aneka Tambang (Persero) Tbk | CID001397 | INDONESIA |
| Gold | PX Precinox S.A. | CID001498 | SWITZERLAND |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter ID | Country Location |
| Gold | Rand Refinery (Pty) Ltd. | CID001512 | SOUTH AFRICA |
| Gold | REMONDIS PMR B.V. | CID002582 | NETHERLANDS |
| Gold | Royal Canadian Mint | CID001534 | CANADA |
| Gold | SAAMP | CID002761 | FRANCE |
| Gold | Safimet S.p.A | CID002973 | ITALY |
| Gold | SAFINA A.S. | CID002290 | CZECHIA |
| Gold | SEMPSA Joyeria Plateria S.A. | CID001585 | SPAIN |
| Gold | Shandong Gold Smelting Co., Ltd. | CID001916 | CHINA |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CID001622 | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CID001736 | CHINA |
| Gold | Solar Applied Materials Technology Corp. | CID001761 | TAIWAN, PROVINCE OF CHINA |
| Gold | Sumitomo Metal Mining Co., Ltd. | CID001798 | JAPAN |
| Gold | SungEel HiMetal Co., Ltd. | CID002918 | KOREA, REPUBLIC OF |
| Gold | T.C.A S.p.A | CID002580 | ITALY |
| Gold | Tanaka Kikinzoku Kogyo K.K. | CID001875 | JAPAN |
| Gold | Tokuriki Honten Co., Ltd. | CID001938 | JAPAN |
| Gold | TOO Tau-Ken-Altyn | CID002615 | KAZAKHSTAN |
| Gold | Torecom | CID001955 | KOREA, REPUBLIC OF |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | CID001980 | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | CID001993 | UNITED STATES OF AMERICA |
| Gold | Valcambi S.A. | CID002003 | SWITZERLAND |
| Gold | Western Australian Mint (T/a The Perth Mint) | CID002030 | AUSTRALIA |
| Gold | WIELAND Edelmetalle GmbH | CID002778 | GERMANY |
| Gold | Yamakin Co., Ltd. | CID002100 | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | CID002129 | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CID002224 | CHINA |
| Gold | ABC Refinery Pty Ltd. | CID002920 | AUSTRALIA |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CID000343 | CHINA |
| Gold | Gold Coast Refinery | CID003186 | GHANA |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CID001909 | CHINA |
| Gold | Kyrgyzaltyn JSC | CID001029 | KYRGYZSTAN |
| Gold | WEEEREFINING | CID003615 | FRANCE |
| Gold | Sam Precious Metals | CID003666 | UNITED ARAB EMIRATES |
| Gold | Coimpa Industrial LTDA | CID004010 | BRAZIL |
| Tantalum | AMG Brasil | CID001076 | BRAZIL |
| Tantalum | D Block Metals, LLC | CID002504 | UNITED STATES OF AMERICA |
| Tantalum | F&X Electro-Materials Ltd. | CID000460 | CHINA |
| Tantalum | FIR Metals & Resource Ltd. | CID002505 | CHINA |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter ID | Country Location |
| Tantalum | Global Advanced Metals Aizu | CID002558 | JAPAN |
| Tantalum | Global Advanced Metals Boyertown | CID002557 | UNITED STATES OF AMERICA |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CID002492 | CHINA |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CID002512 | CHINA |
| Tantalum | Jiangxi Tuohong New Raw Material | CID002842 | CHINA |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CID000914 | CHINA |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CID000917 | CHINA |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CID002506 | CHINA |
| Tantalum | KEMET de Mexico | CID002539 | MEXICO |
| Tantalum | Materion Newton Inc. | CID002548 | UNITED STATES OF AMERICA |
| Tantalum | Metallurgical Products India Pvt., Ltd. | CID001163 | INDIA |
| Tantalum | Mineracao Taboca S.A. | CID001175 | BRAZIL |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | CID001192 | JAPAN |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CID001277 | CHINA |
| Tantalum | NPM Silmet AS | CID001200 | ESTONIA |
| Tantalum | QuantumClean | CID001508 | UNITED STATES OF AMERICA |
| Tantalum | Resind Industria e Comercio Ltda. | CID002707 | BRAZIL |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. | CID003583 | CHINA |
| Tantalum | Taki Chemical Co., Ltd. | CID001869 | JAPAN |
| Tantalum | TANIOBIS Co., Ltd. | CID002544 | THAILAND |
| Tantalum | TANIOBIS GmbH | CID002545 | GERMANY |
| Tantalum | TANIOBIS Japan Co., Ltd. | CID002549 | JAPAN |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | CID002550 | GERMANY |
| Tantalum | Telex Metals | CID001891 | UNITED STATES OF AMERICA |
| Tantalum | Ulba Metallurgical Plant JSC | CID001969 | KAZAKHSTAN |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CID000616 | CHINA |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CID002508 | CHINA |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CID001522 | CHINA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CID000211 | CHINA |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CID000291 | CHINA |
| Tantalum | PowerX Ltd. | CID004054 | RWANDA |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CID003191 | CHINA |
| Tin | Alpha | CID000292 | UNITED STATES OF AMERICA |
| Tin | Aurubis Beerse | CID002773 | BELGIUM |
| Tin | Aurubis Berango | CID002774 | SPAIN |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter ID | Country Location |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CID000228 | CHINA |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CID003190 | CHINA |
| Tin | China Tin Group Co., Ltd. | CID001070 | CHINA |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda | CID003486 | BRAZIL |
| Tin | CRM Synergies | CID003524 | SPAIN |
| Tin | CV Ayi Jaya | CID002570 | INDONESIA |
| Tin | CV Venus Inti Perkasa | CID002455 | INDONESIA |
| Tin | Dowa | CID000402 | JAPAN |
| Tin | DS Myanmar | CID003831 | MYANMAR |
| Tin | EM Vinto | CID000438 | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | Estanho de Rondonia S.A. | CID000448 | BRAZIL |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. | CID003582 | BRAZIL |
| Tin | Fenix Metals | CID000468 | POLAND |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CID000538 | CHINA |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CID003116 | CHINA |
| Tin | Jiangxi New Nanshan Technology Ltd. | CID001231 | CHINA |
| Tin | Luna Smelter, Ltd. | CID003387 | RWANDA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | CID002468 | BRAZIL |
| Tin | Malaysia Smelting Corporation (MSC) | CID001105 | MALAYSIA |
| Tin | Metallic Resources, Inc. | CID001142 | UNITED STATES OF AMERICA |
| Tin | Mineracao Taboca S.A. | CID001173 | BRAZIL |
| Tin | Minsur | CID001182 | PERU |
| Tin | Mitsubishi Materials Corporation | CID001191 | JAPAN |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | CID001314 | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | CID002517 | PHILIPPINES |
| Tin | Operaciones Metalurgicas S.A. | CID001337 | BOLIVIA (PLURINATIONAL STATE OF) |
| Tin | PT Aries Kencana Sejahtera | CID000309 | INDONESIA |
| Tin | PT Artha Cipta Langgeng | CID001399 | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | CID002503 | INDONESIA |
| Tin | PT Babel Inti Perkasa | CID001402 | INDONESIA |
| Tin | PT Babel Surya Alam Lestari | CID001406 | INDONESIA |
| Tin | PT Bangka Serumpun | CID003205 | INDONESIA |
| Tin | PT Bukit Timah | CID001428 | INDONESIA |
| Tin | PT Cipta Persada Mulia | CID002696 | INDONESIA |
| Tin | PT Menara Cipta Mulia | CID002835 | INDONESIA |
| Tin | PT Mitra Stania Prima | CID001453 | INDONESIA |
| Tin | PT Mitra Sukses Globalindo | CID003449 | INDONESIA |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter ID | Country Location |
| Tin | PT Prima Timah Utama | CID001458 | INDONESIA |
| Tin | PT Putera Sarana Shakti (PT PSS) | CID003868 | INDONESIA |
| Tin | PT Rajawali Rimba Perkasa | CID003381 | INDONESIA |
| Tin | PT Rajehan Ariq | CID002593 | INDONESIA |
| Tin | PT Refined Bangka Tin | CID001460 | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | CID001463 | INDONESIA |
| Tin | PT Stanindo Inti Perkasa | CID001468 | INDONESIA |
| Tin | PT Sukses Inti Makmur (SIM) | CID002816 | INDONESIA |
| Tin | PT Timah Nusantara | CID001486 | INDONESIA |
| Tin | PT Timah Tbk Kundur | CID001477 | INDONESIA |
| Tin | PT Timah Tbk Mentok | CID001482 | INDONESIA |
| Tin | PT Tinindo Inter Nusa | CID001490 | INDONESIA |
| Tin | PT Tommy Utama | CID001493 | INDONESIA |
| Tin | Resind Industria e Comercio Ltda. | CID002706 | BRAZIL |
| Tin | Rui Da Hung | CID001539 | TAIWAN, PROVINCE OF CHINA |
| Tin | Super Ligas | CID002756 | BRAZIL |
| Tin | Thaisarco | CID001898 | THAILAND |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. | CID002180 | CHINA |
| Tin | Tin Technology & Refining | CID003325 | UNITED STATES OF AMERICA |
| Tin | White Solder Metalurgia e Mineracao Ltda. | CID002036 | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CID002158 | CHINA |
| Tin | Precious Minerals and Smelting Limited | CID003409 | INDIA |
| Tin | PT Bangka Prima Tin | CID002776 | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | CID001421 | INDONESIA |
| Tin | PT Premium Tin Indonesia | CID000313 | INDONESIA |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. | CID003397 | CHINA |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CID002844 | CHINA |
| Tin | Mining Minerals Resources SARL | CID004065 | CONGO, DEMOCRATIC REPUBLIC OF THE |
| Tin | Soft Metais Ltda. | CID001758 | BRAZIL |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | CID004403 | JAPAN |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | CID002574 | VIET NAM |
| Tin | An Vinh Joint Stock Mineral Processing Company | CID002703 | VIET NAM |
| Tungsten | A.L.M.T. Corp. | CID000004 | JAPAN |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | CID002502 | VIET NAM |
| Tungsten | China Molybdenum Tungsten Co., Ltd. | CID002641 | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CID000258 | CHINA |
| Tungsten | Cronimet Brasil Ltda | CID003468 | BRAZIL |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter ID | Country Location |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. | CID003609 | CHINA |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CID002315 | CHINA |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CID002494 | CHINA |
| Tungsten | Global Tungsten & Powders LLC | CID000568 | UNITED STATES OF AMERICA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CID000218 | CHINA |
| Tungsten | H.C. Starck Tungsten GmbH | CID002541 | GERMANY |
| Tungsten | Hubei Green Tungsten Co., Ltd. | CID003417 | CHINA |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CID000766 | CHINA |
| Tungsten | Hunan Jintai New Material Co., Ltd. | CID000769 | CHINA |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch | CID002513 | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | CID000825 | JAPAN |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CID002551 | CHINA |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CID002321 | CHINA |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CID002318 | CHINA |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CID002317 | CHINA |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CID002316 | CHINA |
| Tungsten | Kennametal Fallon | CID000966 | UNITED STATES OF AMERICA |
| Tungsten | Kennametal Huntsville | CID000105 | UNITED STATES OF AMERICA |
| Tungsten | Lianyou Metals Co., Ltd. | CID003407 | TAIWAN, PROVINCE OF CHINA |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CID002319 | CHINA |
| Tungsten | Masan High-Tech Materials | CID002543 | VIET NAM |
| Tungsten | Niagara Refining LLC | CID002589 | UNITED STATES OF AMERICA |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | CID002827 | PHILIPPINES |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | CID002542 | GERMANY |
| Tungsten | Wolfram Bergbau und Hutten AG | CID002044 | AUSTRIA |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CID002320 | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CID002082 | CHINA |
| Tungsten | Tungsten Vietnam Joint Stock Company | CID003993 | VIET NAM |
SMELTERS NOT CURRENTLY CERTIFED CONFORMANT
This list contains smelters that are not certified conformant, reported by Zebra suppliers using
2023 RMI Conflict Minerals Reporting Template v6.31.
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter ID | Country Location |
| Gold | Alexy Metals | CID003500 | UNITED STATES OF AMERICA |
| Gold | Augmont Enterprises Private Limited | CID003461 | INDIA |
| Gold | Emirates Gold DMCC | CID002561 | UNITED ARAB EMIRATES |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. | CID002852 | INDIA |
| Gold | Samduck Precious Metals | CID001555 | KOREA, REPUBLIC OF |
| Gold | Singway Technology Co., Ltd. | CID002516 | TAIWAN, PROVINCE OF CHINA |
| Gold | Umicore Precious Metals Thailand | CID002314 | THAILAND |
| Gold | Albino Mountinho Lda. | CID002760 | PORTUGAL |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | CID000103 | TURKEY |
| Gold | AU Traders and Refiners | CID002850 | SOUTH AFRICA |
| Gold | Caridad | CID000180 | MEXICO |
| Gold | CGR Metalloys Pvt Ltd. | CID003382 | INDIA |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | CID002867 | GERMANY |
| Gold | Dijllah Gold Refinery FZC | CID003348 | UNITED ARAB EMIRATES |
| Gold | Dongwu Gold Group | CID003663 | CHINA |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | CID003487 | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | CID003488 | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | CID003489 | INDIA |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | CID003490 | INDIA |
| Gold | Fujairah Gold FZC | CID002584 | UNITED ARAB EMIRATES |
| Gold | Guangdong Jinding Gold Limited | CID002312 | CHINA |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CID000651 | CHINA |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CID000671 | CHINA |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CID000767 | CHINA |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CID000773 | CHINA |
| Gold | HwaSeong CJ CO., LTD. | CID000778 | KOREA, REPUBLIC OF |
| Gold | International Precious Metal Refiners | CID002562 | UNITED ARAB EMIRATES |
| Gold | JALAN & Company | CID002893 | INDIA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | CID000927 | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | CID000929 | RUSSIAN FEDERATION |
| Gold | K.A. Rasmussen | CID003497 | NORWAY |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter ID | Country Location |
| Gold | Kaloti Precious Metals | CID002563 | UNITED ARAB EMIRATES |
| Gold | Kazakhmys Smelting LLC | CID000956 | KAZAKHSTAN |
| Gold | Kundan Care Products Ltd. | CID003463 | INDIA |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | CID002865 | RUSSIAN FEDERATION |
| Gold | L'azurde Company For Jewelry | CID001032 | SAUDI ARABIA |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CID001058 | CHINA |
| Gold | Marsam Metals | CID002606 | BRAZIL |
| Gold | MD Overseas | CID003548 | INDIA |
| Gold | Metallix Refining Inc. | CID003557 | UNITED STATES OF AMERICA |
| Gold | Modeltech Sdn Bhd | CID002857 | MALAYSIA |
| Gold | Morris and Watson | CID002282 | NEW ZEALAND |
| Gold | Moscow Special Alloys Processing Plant | CID001204 | RUSSIAN FEDERATION |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | CID001326 | RUSSIAN FEDERATION |
| Gold | JSC Novosibirsk Refinery | CID000493 | RUSSIAN FEDERATION |
| Gold | Pease & Curren | CID002872 | UNITED STATES OF AMERICA |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CID001362 | CHINA |
| Gold | Prioksky Plant of Non-Ferrous Metals | CID001386 | RUSSIAN FEDERATION |
| Gold | QG Refining, LLC | CID003324 | UNITED STATES OF AMERICA |
| Gold | Refinery of Seemine Gold Co., Ltd. | CID000522 | CHINA |
| Gold | Sabin Metal Corp. | CID001546 | UNITED STATES OF AMERICA |
| Gold | Sai Refinery | CID002853 | INDIA |
| Gold | SAMWON METALS Corp. | CID001562 | KOREA, REPUBLIC OF |
| Gold | Shandong Humon Smelting Co., Ltd. | CID002525 | CHINA |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CID001619 | CHINA |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | CID002750 | CHINA |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | CID002527 | CHINA |
| Gold | Shirpur Gold Refinery Ltd. | CID002588 | INDIA |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | CID001756 | RUSSIAN FEDERATION |
| Gold | Sovereign Metals | CID003383 | INDIA |
| Gold | State Research Institute Center for Physical Sciences and Technology | CID003153 | LITHUANIA |
| Gold | Super Dragon Technology Co., Ltd. | CID001810 | TAIWAN, PROVINCE OF CHINA |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CID001947 | CHINA |
| Gold | Yunnan Copper Industry Co., Ltd. | CID000197 | CHINA |
| Gold | African Gold Refinery | CID003185 | UGANDA |
| Gold | Fidelity Printers and Refiners Ltd. | CID002515 | ZIMBABWE |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter ID | Country Location |
| Gold | Industrial Refining Company | CID002587 | BELGIUM |
| Gold | Lingbao Gold Co., Ltd. | CID001056 | CHINA |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CID001093 | CHINA |
| Gold | Sudan Gold Refinery | CID002567 | SUDAN |
| Tantalum | 5D Production OU | CID003926 | ESTONIA |
| Tantalum | Solikamsk Magnesium Works OAO | CID001769 | RUSSIAN FEDERATION |
| Tantalum | Exotech Inc. | CID000456 | UNITED STATES OF AMERICA |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CID000555 | CHINA |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | CID003356 | CHINA |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | CID002572 | VIET NAM |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | CID003410 | CHINA |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CID000942 | CHINA |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CID001908 | CHINA |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | CID003379 | CHINA |
| Tin | Melt Metais e Ligas S.A. | CID002500 | BRAZIL |
| Tin | Modeltech Sdn Bhd | CID002858 | MALAYSIA |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | CID002573 | VIET NAM |
| Tin | Novosibirsk Tin Combine | CID001305 | RUSSIAN FEDERATION |
| Tin | PT Bangka Tin Industry | CID001419 | INDONESIA |
| Tin | PT Panca Mega Persada | CID001457 | INDONESIA |
| Tin | PT Tirus Putra Mandiri | CID002478 | INDONESIA |
| Tin | VQB Mineral and Trading Group JSC | CID002015 | VIET NAM |
| Tin | Pongpipat Company Limited | CID003208 | MYANMAR |
| Tungsten | ACL Metais Eireli | CID002833 | BRAZIL |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | CID003427 | BRAZIL |
| Tungsten | Artek LLC | CID003553 | RUSSIAN FEDERATION |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | CID000281 | CHINA |
| Tungsten | HANNAE FOR T Co., Ltd. | CID003978 | KOREA, REPUBLIC OF |
| Tungsten | Hydrometallurg, JSC | CID002649 | RUSSIAN FEDERATION |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CID002313 | CHINA |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | CID003408 | RUSSIAN FEDERATION |
| Tungsten | LLC Vostok | CID003643 | RUSSIAN FEDERATION |
| Tungsten | Moliren Ltd. | CID002845 | RUSSIAN FEDERATION |
| | | | | | | | | | | |
| Metal | Smelter Name | Smelter ID | Country Location |
| Tungsten | NPP Tyazhmetprom LLC | CID003416 | RUSSIAN FEDERATION |
| Tungsten | OOO “Technolom” 1 | CID003614 | RUSSIAN FEDERATION |
| Tungsten | OOO “Technolom” 2 | CID003612 | RUSSIAN FEDERATION |
| Tungsten | Unecha Refractory Metals Plant | CID002724 | RUSSIAN FEDERATION |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | CID003662 | CHINA |
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