Exhibit 1.01
MaxLinear, Inc.
Conflict Minerals Report
For The Year Ended December 31, 2021
Cautionary Note Concerning Forward-Looking Statements: This Conflict Minerals Report contains forward-looking statements within the meaning of federal securities laws. These forward-looking statements include statements concerning MaxLinear’s objectives for its conflict minerals policy and compliance initiatives and actions it intends to take relating to conflict minerals. Forward-looking statements involve substantial risks and uncertainties that could cause actual results to differ materially from currently anticipated results. When considering forward-looking statements, you should consider, among other factors, the risk factors described in the reports and other filings that MaxLinear files with the United States Securities and Exchange Commission, including MaxLinear’s Annual Report on Form 10-K for the year ended December 31, 2021 and its subsequent Quarterly Reports on Form 10-Q. The risk factors included in these filings are not exhaustive, and risks that are not identified therein could materially affect whether MaxLinear realizes the results anticipated or implied by any forward-looking statements contained in this Conflict Minerals Report. Except as required by law, MaxLinear disclaims any obligation to update these forward-looking statements, whether as a result of new information, future events, or otherwise.
Introduction
This Conflict Minerals Report (this “Report”) for MaxLinear, Inc. (“MaxLinear” or “we” or “our”) covers the reporting period from January 1, 2021 to December 31, 2021 and is presented in accordance with Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended (“Rule 13p-1”). This Report is filed as Exhibit 1.01 to our Specialized Disclosure Report on Form SD (the “Form SD”). A copy of this Report and the Form SD are publicly available on our website at https://investors.maxlinear.com/sec-filings.
In 2010, the United States enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Act”). Section 1502 of the Act related to conflict minerals and requires companies subject to the Act to file a Form SD annually with the United States Securities and Exchange Commission (“SEC”) to disclose whether the tungsten, tantalum, tin, and gold (referred to collectively as “3TG”) used in their products benefited, directly or indirectly, armed groups in the Democratic Republic of the Congo and adjoining countries (collectively, the “Covered Countries”). This Report, which is an exhibit to our Form SD, describes the design and implementation of our conflict minerals due diligence measures undertaken in 2021, including a description of how these measures were designed to determine, to our knowledge, the source mines, countries of origin, and processing facilities for 3TG contained in components used in MaxLinear’s products.
Background and Covered Products
MaxLinear is a provider of communications systems-on-chip (SoC) solutions used in broadband, mobile and wireline infrastructure, data center, and industrial and multi-market applications. As a fabless integrated circuit design company, we do not manufacture our products but contract for their manufacture through semiconductor foundries generally located in Asia. Our supply chain is complex, and multiple tiers exist between the mines from which 3TG are extracted and its incorporation into our products. We do not purchase raw ore or unrefined 3TG directly and make no purchases in the Covered Countries. As a result and as described more fully below, we rely on our foundries and suppliers to provide information on the origin of the 3TG contained in our products.
MaxLinear Covered Products
During 2021, MaxLinear contracted to manufacture and had manufactured a total of 1,048 integrated circuit products, or IC Products, (as measured by individual stock keeping units or SKUs) for our markets. We currently provide several types of broadband and communications semiconductor devices: radio frequency, or RF, receivers and RF Receiver System on Chip, or RF Receiver SoCs; wireless infrastructure backhaul RF receivers and modem SoCs; transimpedance amplifiers, or TIA’s; laser modulator drivers; clock and data recovery circuits; interface solutions; power management; and date encryption and compression. Our semiconductor solutions combine various analog and mixed-signal technologies and functionality that traditionally required the use of multiple external discrete components. Substantially all of MaxLinear’s revenues in calendar year 2021 were generated through sales of integrated circuit products.
MaxLinear also provides evaluation or demonstration circuit boards, or Board Products, to customers or prospective customers to allow them to test or validate MaxLinear’s IC products. Board Products are marketing or business development tools that facilitate the sale of MaxLinear’s IC Products. Because of their limited application, Board Products are manufactured and sold in very small quantities. Board Products are either assembled at MaxLinear facilities or manufactured for MaxLinear by third party
suppliers. The supplier base for Board Products varies widely and includes many small suppliers, including printed circuit board manufacturers, component distributors, component manufacturers and manufacturers of custom made hardware such as RF filters, connectors, cables, etc. The sales of Board Products represented less than 1% of MaxLinear’s revenues in calendar year 2021.
Reasonable Country of Origin Inquiry
In accordance with Rule 13p-1 and Form SD, MaxLinear determined that 3TG are necessary to the functionality or production of its integrated circuit products and that 3TG are incorporated into its products during the manufacturing process. Accordingly, we undertook a reasonable country of origin inquiry (“RCOI”).
MaxLinear’s RCOI consisted principally of submitting to its suppliers the conflict minerals reporting template (the “RMI Template”) prepared by the Responsible Minerals Initiative (“RMI”), an initiative of the Responsible Business Alliance and Global e-Sustainability Initiative. MaxLinear submitted the RMI Template to all of its contract manufacturers and all of its first tier suppliers of components. MaxLinear then reviewed all responses for completeness, reasonableness, and consistency, and followed up for corrections and clarifications as MaxLinear determined appropriate.
Based on MaxLinear’s RCOI, MaxLinear was unable to determine that the 3TG used in its products did not originate in Covered Countries.
Due Diligence Process
MaxLinear’s due diligence measures were designed to conform, in all material respects, with the framework in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (the “OECD Framework”). The objectives of our diligence initiative were to determine, to the best of our ability, the source and chain of custody of the 3TG necessary for the functionality and/or production of our products; whether any such 3TG originated in the Covered Countries; and where such 3TG were determined to have originated in Covered Countries, whether armed groups directly or indirectly benefitted from such 3TG.
Due diligence measures undertaken by MaxLinear included, but were not limited to, the following:
1. Establishment of Internal Management Systems
a. Conflict Minerals Policy. In 2013, MaxLinear adopted and communicated to its foundries and suppliers a written policy relating to the use of conflict minerals in its supply chain. A copy of MaxLinear’s Conflict Minerals Policy is publicly available at https://www.maxlinear.com/support/quality/conflict-mineral-policy.
b. Internal Management to Support Supply Chain Due Diligence. MaxLinear has established an internal compliance team with members from its operations, finance, and legal functions, and these individuals are charged with the management of our conflict minerals program.
c. Controls and Transparency. As described above, MaxLinear undertook an RCOI with respect to conflict minerals in our supply chain by providing the RMI Template to each of our contract manufacturers and other first tier suppliers to gather information about their use of 3TG, the smelters and refiners in their supply chain that are included in our products, and the countries of origin for 3TG used in our products.
d. Supplier Engagement. MaxLinear continues to engage actively with its foundries and other first tier suppliers to strengthen its relationship with them. We have communicated to our foundries and other suppliers our commitment to source 3TG in a manner that does not, directly or indirectly, benefit armed groups in the Covered Countries, and we have communicated that we will consider alternative arrangements with other manufacturers or suppliers who are unable to cooperate in our due diligence efforts.
e. Grievance Mechanism. MaxLinear’s code of conduct includes procedures for reporting violations, and we provide mechanisms for anonymous reporting of violations or concerns about the conduct of our business, including our implementation and enforcement of our Conflict Minerals Policy.
2. Identification and Assessment of Risks in the Supply Chain
Because of our position within our supply chain, identifying actors upstream from our first tier contract manufacturers and suppliers is difficult. As discussed above, we identified our foundries and first tier suppliers and relied on them to provide the necessary information about the source of conflict minerals contained in the products that we contract to have manufactured. Similarly, our foundries and first tier suppliers rely on information provided by their suppliers to provide information regarding the country of origin of 3TG included in our products.
3. Designing and Implementing a Strategy to Respond to Identified Risks
We have developed a formal risk management plan through which our conflict minerals program is implemented, managed, and monitored. During calendar years 2013 to 2021 and continuing into 2022, where foundries or suppliers
were unable to provide MaxLinear with complete or reliable responses to the RMI Template, we considered these matters internally. To date, we have not identified any circumstances where we concluded that it was necessary to terminate any contract or relationship or find a replacement manufacturer or supplier as a result of conflict minerals matters.
4. Carrying Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not have a direct relationship with any smelters or refiners in our supply chain. As a result, we do not and cannot conduct any audits directly. Instead, we support the development and implementation of independent third party audits of smelters such as the RMI’s Responsible Minerals Assurance Process (“RMAP”) by encouraging our foundries and other suppliers to purchase materials from audited smelters that have been validated as conflict-free under the RMAP.
5. Reporting on Supply Chain Due Diligence
In May 2022, we publicly filed the Form SD and this Report with the SEC. A copy of this Report and the Form SD are publicly available at https://investors.maxlinear.com/sec-filings. This Report includes information about the RCOI methodology utilized by the Company, the design of our due diligence process in conformance with the OECD Framework, the list of known smelters and refiners utilized in our supply chain identified in our due diligence process, and a description of our products that incorporate 3TG necessary to the functionality or production of such products.
Smelters and Refiners in Supply Chain
We adopted RMI’s industry approach to trace back the origin of 3TG by identifying smelters, refineries, or recyclers and scrap supplier sources through our supply chain survey results. MaxLinear leveraged RMI and the RMAP to trace the mine of origin of the 3TG to its ore level. The RMAP audits smelters and refineries to ensure that all certified smelters and refineries use only the ores that are conflict free from the Covered Countries. Based on information that was provided by our foundries and other first tier suppliers or that was otherwise obtained through our due diligence process, we believe, to the extent reasonably determinable, that the following facilities were used to process 3TG contained in our covered products.
We have also provided information concerning whether the smelter participates in the RMAP and has been audited or whether it has agreed to participate in the RMAP but the audit process has not yet been completed.
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| Metal | Smelter or Refiner Name | Country | RMAP Status* |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | C |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | C |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | C |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | C |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | C |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | C |
| Gold | Asahi Pretec Corp. | JAPAN | C |
| Gold | Asaka Riken Co., Ltd. | JAPAN | C |
| Gold | Aurubis AG | GERMANY | C |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | C |
| Gold | Boliden AB | SWEDEN | C |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | C |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | C |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | C |
| Gold | Chimet S.p.A. | ITALY | C |
| Gold | Chugai Mining | JAPAN | C |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | C |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | C |
| Gold | Dowa | JAPAN | C |
| Gold | Eco-System Recycling Co., Ltd. East Plant | JAPAN | C |
| Gold | LT Metal Ltd. | KOREA, REPUBLIC OF | C |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | C |
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| Metal | Smelter or Refiner Name | Country | RMAP Status* |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | C |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | C |
| Gold | Istanbul Gold Refinery | TURKEY | C |
| Gold | Japan Mint | JAPAN | C |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | C |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | C |
| Gold | Asahi Refining Canada Ltd. | CANADA | C |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | C |
| Gold | Kazzinc | KAZAKHSTAN | C |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | C |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | C |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | C |
| Gold | Materion | UNITED STATES OF AMERICA | C |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | C |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | C |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | C |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | C |
| Gold | Metalor Technologies S.A. | SWITZERLAND | C |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | C |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | C |
| Gold | Mitsubishi Materials Corporation | JAPAN | C |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | C |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | C |
| Gold | Nihon Material Co., Ltd. | JAPAN | C |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | C |
| Gold | PAMP S.A. | SWITZERLAND | C |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | C |
| Gold | PX Precinox S.A. | SWITZERLAND | C |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | C |
| Gold | Royal Canadian Mint | CANADA | C |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | C |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | C |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | C |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | C |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, REPUBLIC OF CHINA | C |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | C |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | C |
| Gold | Shandong Gold Smelting Co., Ltd. | CHINA | C |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | C |
| Gold | Torecom | KOREA, REPUBLIC OF | C |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | C |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | C |
| Gold | Valcambi S.A. | SWITZERLAND | C |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | C |
| Gold | Yamakin Co., Ltd. | JAPAN | C |
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| Metal | Smelter or Refiner Name | Country | RMAP Status* |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | C |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | C |
| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | C |
| Gold | Umicore Precious Metals Thailand | THAILAND | C |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | C |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | C |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | C |
| Gold | Singway Technology Co., Ltd. | TAIWAN, REPUBLIC OF CHINA | C |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | C |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | C |
| Gold | T.C.A S.p.A | ITALY | C |
| Gold | T.C.A S.p.A | ITALY | C |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | C |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | C |
| Gold | Marsam Metals | BRAZIL | C |
| Gold | SAAMP | FRANCE | C |
| Gold | L'Orfebre S.A. | ANDORRA | C |
| Gold | 8853 S.p.A. | ITALY | C |
| Gold | Italpreziosi | ITALY | C |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | C |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | C |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | C |
| Gold | Bangalore Refinery | INDIA | C |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | C |
| Gold | Planta Recuperadora de Metales SpA | CHILE | C |
| Gold | Safimet S.p.A | ITALY | C |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | C |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | C |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | C |
| Tantalum | F&X Electro-Materials Ltd. | CHINA | C |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED | CHINA | C |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | C |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | C |
| Tantalum | LSM Brasil S.A. | BRAZIL | C |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | C |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | C |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | C |
| Tantalum | NPM Silmet AS | ESTONIA | C |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | C |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | C |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | C |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | C |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | C |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | C |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | C |
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| Metal | Smelter or Refiner Name | Country | RMAP Status* |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | C |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | C |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | C |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | C |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | C |
| Tantalum | KEMET de Mexico | MEXICO | C |
| Tantalum | TANIOBIS Co., Ltd. | THAILAND | C |
| Tantalum | TANIOBIS GmbH | GERMANY | C |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | C |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | C |
| Tantalum | TANIOBIS Japan Co., Ltd. | JAPAN | C |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG | GERMANY | C |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | C |
| Tantalum | Global Advanced Metals Aizu | JAPAN | C |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | C |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | C |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | C |
| Tin | Alpha | UNITED STATES OF AMERICA | C |
| Tin | Dowa | JAPAN | C |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | C |
| Tin | Fenix Metals | POLAND | C |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | C |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | C |
| Tin | China Tin Group Co., Ltd. | CHINA | C |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | C |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | C |
| Tin | Mineracao Taboca S.A. | BRAZIL | C |
| Tin | Minsur | PERU | C |
| Tin | Mitsubishi Materials Corporation | JAPAN | C |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | C |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | C |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | C |
| Tin | PT Artha Cipta Langgeng | INDONESIA | C |
| Tin | PT Mitra Stania Prima | INDONESIA | C |
| Tin | PT Refined Bangka Tin | INDONESIA | C |
| Tin | PT Timah Tbk Kundur | INDONESIA | C |
| Tin | PT Timah Tbk Mentok | INDONESIA | C |
| Tin | Rui Da Hung | TAIWAN, REPUBLIC OF CHINA | C |
| Tin | Soft Metais Ltda. | BRAZIL | C |
| Tin | Thaisarco | THAILAND | C |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | C |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | C |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | C |
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| Metal | Smelter or Refiner Name | Country | RMAP Status* |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | C |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | C |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | C |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | C |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | C |
| Tin | Metallo Belgium N.V. | BELGIUM | C |
| Tin | Metallo Spain S.L.U. | SPAIN | C |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | VIETNAM | C |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | C |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | C |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | C |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | C |
| Tungsten | A.L.M.T. Corp. | JAPAN | C |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | C |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | C |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | C |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | C |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | C |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | C |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | C |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | C |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | C |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | C |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | C |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | C |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | C |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | C |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | C |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | C |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | C |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | C |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | C |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | C |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIETNAM | C |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | C |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | C |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG | GERMANY | C |
| Tungsten | Masan High-Tech Materials | VIETNAM | C |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | C |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | C |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | C |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | C |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | C |
| Tungsten | ACL Metais Eireli | BRAZIL | C |
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| Metal | Smelter or Refiner Name | Country | RMAP Status* |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | C |
| Tungsten | KGETS Co., Ltd. | KOREA, REPUBLIC OF | C |
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| * | This column indicates whether the known smelter or refiner participates in the RMAP as a smelter that sources conflict minerals in a manner that does not finance or benefit armed groups in the Covered Countries. For purposes of this column, “C” denotes that the smelter participates in the RMAP and successfully completed an assessment against the applicable RMAP standard or an equivalent cross-recognized assessment to be deemed “Conformant”, “A” denotes that the smelter has agreed to participate in the RMAP but that the audit process has not yet been completed as of May 26, 2021, and “U” denotes that the smelter or refinery has not received a “conflict free” designation from an independent third party audit program or the facility’s receipt of such designation is undeterminable. |
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Future Steps
We have communicated our expectations to our foundries and other first tier suppliers regarding our commitment to sourcing minerals for our products in a manner that does not, directly or indirectly, finance or benefit armed groups in the DRC or adjoining countries. Since the end of 2013, we have continued, and expect to continue to increase our engagement with our relevant manufacturing foundries and first tier suppliers in order to build their knowledge and capacity so they are able to provide MaxLinear with more complete and accurate information on the source and chain of custody of conflict minerals.