Document




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

Commission File No. 0-12695


Integrated Device Technology, Inc.
(Exact Name of Registrant as Specified in Its Charter)

 
Delaware
(State or Other Jurisdiction of Incorporation or Organization)    
 
 
94-2669985
 (I.R.S. Employer Identification No.)
 
 
 
 
 
 
 
 
6024 Silver Creek Valley Road, San Jose, California
(Address of Principal Executive Offices)
 
95138
(Zip Code)
 


Name and Telephone Number, Including Area Code of the Person to Contact in Connection with this Report:
Matthew Brandalise, Vice President & General Counsel, (408) 284-8200

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 for the reporting period from January 1 to December 31, 2017






























Section 1:     IDT Form SD and Conflict Minerals Report for Calendar Year 2017
Item 1.01     Summary of Conflict Minerals Disclosure and Report

Introduction
This Form SD of Integrated Device Technology, Inc. (“IDT” or “we” or the “Company”) covering the calendar year reporting period ended December 31, 2017, is filed with the Securities and Exchange Commission (“SEC”) pursuant to Section 13 (p) of the Securities Exchange Act of 1934, as amended (“Exchange Act”), and Rule 13 p-1 and Form SD thereunder. Section 13 (p) was added to the Exchange Act by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, and directed the SEC to adopt rules in the form of Rule 13 p-1 and Form SD (together the “Rule”). The Rule, as now in effect, requires disclosure of certain information by companies that manufacture or contract to manufacture products for which certain minerals specified in Section 13(p) and the Rule are necessary to the functionality or production of those products. These designated “conflict minerals” are gold, tin, tantalum and tungsten (“3TG”). The term “Covered Countries” for purposes of the Rule are the Democratic Republic of the Congo (“DRC”), and the following nine adjoining countries: The Republic of the Congo, the Central African Republic, South Sudan, Rwanda, Uganda, Zambia, Burundi, Tanzania and Angola.

IDT understands the DRC and the nine Covered Countries are rich in natural resources. IDT also recognizes that some mining activities in certain regions/mines within the DRC and Covered Countries are controlled by non-government military groups and have been identified by the U.S. Government and other global and industry organizations as potentially contributing to human rights abuses and environmental damage within the region.   IDT is committed to engaging in rigorous due diligence efforts designed to verify the source of tin, tantalum, tungsten, and gold (“3TG Minerals”) used in IDT’s supply chain. IDT is committed to purchasing 3TG Minerals and other materials only from environmentally and socially responsible suppliers.  
IDT has determined that certain of its products contain various 3TG Minerals that are necessary to the functionality or production of such products. Accordingly, we were required under the Rule to conduct a good-faith, reasonable country of origin inquiry (“RCOI”), designed to determine whether any of the 3TG Minerals in our products either originated in the Covered Countries or came from recycled or scrap materials. The following is a brief description of the RCOI process IDT undertook in accordance with the Rule.

Reasonable Country of Origin Inquiry (“RCOI”):
To satisfy the RCOI requirement of the Rule, IDT has, in good faith, surveyed its suppliers using the Electronic Industry Citizen Coalition (“EICC”) and the Global e-Sustainability Initiative (“GeSI”) Conflict Minerals Reporting Template. This survey was developed by EICC and GeSI to help companies in the electronics and other industries determine whether any of the designated 3TG Minerals (as defined above) that are necessary to the functionality or production of their products either came from recycled or scrap sources or originated in one or more of the Covered Countries. As part of the RCOI process, we performed a scoping exercise to understand our supply chain, including the relevant supplier and sub-supplier population and the composition of the products or components we procured from such suppliers. We also adopted a framework for evaluating responses from suppliers and identifying potential red flags in suppliers’ responses requiring follow-up inquiries. We also adopted a company level policy statement on conflict minerals which has been published on our website1 at:

http://www.idt.com/about/corporate-responsibility-citizenship/conflict-free-metals-policy

Based on the process described above, we believe that we have conducted a good faith reasonable country of origin inquiry for the calendar year ended December 31, 2017. We have documented our RCOI process, including our analysis of the supplier responses and the scoping of our products to focus on those containing 3TG Minerals, and relevant suppliers for our internal recordkeeping purposes.







__________________________________
1 The content of this website, and any other website referred to in this Form SD and/or the accompanying CMR is not incorporated by reference into either of these documents, or any other document filed or to be filed with the SEC by IDT.










Results of Inquiry:
Based on the RCOI responses and our analysis of such responses, as applied to the calendar year ended December 31, 2017, virtually all of our suppliers were able to ascertain the source mine and country of origin for most of the relevant 3TG Minerals sourced for our products. In only a few cases was a supplier unable to ascertain the source of 3TG Minerals. Therefore, we proceeded to perform reasonable due diligence procedures as required by Section 13 (p) and the Rule for all sources.

Due Diligence on the Source and Chain of Custody of Its Conflict Minerals:
IDT is required to exercise due diligence on the 3TG Minerals’ source and chain of custody pursuant to a nationally or internationally recognized due diligence framework. Our due diligence measures have been designed to conform, in all material respects, with the framework in the Organization for Economic Cooperation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict Affected and High Risk Areas: Second Edition, and the Supplements thereto for gold, tin, tantalum and tungsten (“OECD Due Diligence Guidance”), because the SEC has specified that this is an appropriate nationally or internationally recognized due diligence framework. We have adopted and communicated our conflict mineral policy to our suppliers and customers and have followed RCOI and due diligence procedures to gather information from our new and existing suppliers.2. In addition, there are also programs in place at IDT to encourage our suppliers to source from smelters and refiners subject to rigorous third-party supply chain audits, such as the Conflict-Free Smelter Program established as part of the Conflict-Free Sourcing Initiative. These and other due diligence measures IDT performed in calendar year 2017 are discussed in greater detail in the attached Conflict Minerals Report.

This Form SD and the Conflict Minerals Report, filed as Exhibit 1.02 hereto, are publicly available at:
http://ir.idt.com/financial-information/sec-filings

The content of this and any other website referred to in this Form SD or the accompanying Conflict Minerals Report is not incorporated by reference into either of these documents, or any other document filed by the Company with the SEC.

Item 1.02    Exhibit
The Conflict Minerals Report (“CMR”) required by Item 1.01 is filed as Exhibit 1.02 to this Form SD.

Section 2 - Exhibits
Item 2.01    Exhibit
As noted above, the following exhibit is filed as part of this Form SD:
Exhibit 1.02 - Conflict Minerals Report (“CMR”) as required by Item 1.01 and 1.02 of this Form.





















_____________________________________________
2 IDT’s RCOI and due diligence procedures overlap to a significant degree.










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.

INTEGRATED DEVICE TECHNOLOGY, INC.
By: /s/ Matthew Brandalise
___________________________________________
Matthew Brandalise
Vice President, General Counsel and Secretary

Dated: June 1, 2018




Exhibit

Exhibit 1.02
Integrated Device Technology, Inc.
Conflict Minerals Report for the Calendar Year Ended December 31, 2017

Company Overview:
Integrated Device Technology, Inc. (the “Company” or “IDT”) designs, develops, has manufactured and markets integrated circuit system solutions for the advanced communications, computing, consumer and automotive industries. Its broad range of semiconductor solutions combines analog and digital technology to develop system-level innovations that optimize customers' applications and enrich the end-user experience. IDT uses its market leadership in wireless power, timing, serial switching, sensors and interfaces, and adds analog and systems expertise to provide complete application-optimized, mixed-signal solutions for the market segments in which it competes. Headquartered in San Jose, California, IDT has design, test and sales facilities throughout the world. IDT stock is traded on the NASDAQ Global Select Stock Market® under the symbol "IDTI."

IDT uses third-party foundries that are primarily located in the APAC region to manufacture all of its products. IDT assembles and/or packages products using several different subcontractors in the APAC region.  This enables the Company to negotiate lower prices, and limits the risk associated with production concentration in one country or company.  The criteria used to select assembly subcontractors include, but are not limited to, sourcing from conflict mineral free sources, cost, quality, delivery, and subcontractor financial stability. IDT performs a vast majority of its test operations at its test facility located in Malaysia.  A relatively small number of test operations also are performed at third-party subcontractors in the APAC region.

All IDT products incorporate at least one of the minerals regulated by section 1502: tungsten, tantalum, gold and tin (“3TG Minerals”). Tungsten is present in 100% of the products we sell, and tantalum is present in those products produced through three of our foundries from whom we purchase advanced technology. Gold and tin are used in certain packages for IDT products assembled by the APAC subcontractors with whom IDT contracts.

Our Conflict Minerals Policy:
IDT is committed to complying with the letter and the spirit of the conflict minerals disclosure requirements adopted by the Securities and Exchange Commission (“SEC”) under Section 13 (p) of the Securities and Exchange Act, as amended (the “Act”), in the form of Rule 13p-1 and Form SD (the “Rule”). IDT has considered the Rule’s requirements, guidance from the Organization for Economic Cooperation and Development (the “OECD”) that has been recognized as authoritative by the SEC, and related measures being taken by the EICC/GeSI Extractives Work Group and other organizations, and is implementing and enhancing its formal Conflict Minerals compliance program accordingly. Our Conflict Minerals Policy Statement is available on the IDT.com website at:

http://www.idt.com/about/corporate-responsibility-citizenship/conflict-free-metals-policy

To support this policy, IDT 1) conducts a reasonable country of origin inquiry of its suppliers and, if required by the Rule, implements a program of due diligence on the source and chain of custody of 3TG Minerals necessary to the functionality or production of IDT products; 2) Expects our suppliers to have policies and procedures in place which are in compliance with the IDT Conflict Free Metals Policy Statement, and will enable transparency of the IDT supply chain to facilitate our compliance with the Rule; 3) provides and expects our suppliers to cooperate in providing reasonable country of origin and due diligence information with regard to use of 3TG Minerals in our supply chain.

Efforts to Determine the Mine or Location of Origin of the 3TG Minerals in Our Products
Tracing the 3TG Minerals used in our products back to the mine and source country of origin of each such mineral is a complex but important aspect of responsible sourcing. To help establish our supply chain sourcing programs, we have followed currently established industry guidelines such as the Conflict Free Sourcing Initiative of the EICC and the GeSI (“CFSI”), which are taking action to address responsible sourcing through the development of the Conflict-Free Smelter (“CFS”) program which enables companies to source minerals from conflict-free sources.
Through our reasonable country of origin inquiry (“RCOI”) survey process, we adopted the CFSI’s industry approach and traced back the origin of 3TG inerals by identifying smelters, refineries or recyclers and scrap supplier sources. We also utilized the CFSI and its CFS program to trace the mine of origin of the 3TG minerals when the information was available. The CFS program audits smelters and refineries to ensure that all certified smelters and refineries only use the ore that are conflict free from the DRC and covered countries.

Facilities Used to Process the 3TG Minerals in IDT Products
The table below lists the facilities which, to the extent known, were identified by our supply chain as sourcing smelters or refineries for one or more of the 3TG Minerals in our products.





Metal (*)
Smelter Name (*)
Smelter Country (*)
Smelter Identification
Gold
Advanced Chemical Company
UNITED STATES OF AMERICA
CID000015
Gold
Aida Chemical Industries Co., Ltd.
JAPAN
CID000019
Gold
Al Etihad Gold LLC
UNITED ARAB EMIRATES
CID002560
Gold
Allgemeine Gold-und Silberscheideanstalt A.G.
GERMANY
CID000035
Gold
Almalyk Mining and Metallurgical Complex (AMMC)
UZBEKISTAN
CID000041
Gold
AngloGold Ashanti Corrego do Sitio Mineracao
BRAZIL
CID000058
Gold
Argor-Heraeus S.A.
SWITZERLAND
CID000077
Gold
Asahi Pretec Corp.
JAPAN
CID000082
Gold
Asahi Refining Canada Ltd.
CANADA
CID000924
Gold
Asahi Refining USA Inc.
UNITED STATES OF AMERICA
CID000920
Gold
Asaka Riken Co., Ltd.
JAPAN
CID000090
Gold
AU Traders and Refiners
SOUTH AFRICA
CID002850
Gold
Aurubis AG
GERMANY
CID000113
Gold
Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
PHILIPPINES
CID000128
Gold
Boliden AB
SWEDEN
CID000157
Gold
C. Hafner GmbH + Co. KG
GERMANY
CID000176
Gold
CCR Refinery - Glencore Canada Corporation
CANADA
CID000185
Gold
Chimet S.p.A.
ITALY
CID000233
Gold
The Refinery of Shandong Gold Mining Co., Ltd.
CHINA
CID001916
Gold
Daejin Indus Co., Ltd.
KOREA, REPUBLIC OF
CID000328
Gold
DODUCO Contacts and Refining GmbH
GERMANY
CID000362
Gold
Dowa
JAPAN
CID000401
Gold
DSC (Do Sung Corporation)
KOREA, REPUBLIC OF
CID000359
Gold
Eco-System Recycling Co., Ltd.
JAPAN
CID000425
Gold
Emirates Gold DMCC
UNITED ARAB EMIRATES
CID002561
Gold
Geib Refining Corporation
UNITED STATES OF AMERICA
CID002459
Gold
Gold Refinery of Zijin Mining Group Co., Ltd.
CHINA
CID002243
Gold
Heimerle + Meule GmbH
GERMANY
CID000694
Gold
Heraeus Metals Hong Kong Ltd.
CHINA
CID000707
Gold
Heraeus Precious Metals GmbH & Co. KG
GERMANY
CID000711
Gold
Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
CHINA
CID000801
Gold
Ishifuku Metal Industry Co., Ltd.
JAPAN
CID000807
Gold
Istanbul Gold Refinery
TURKEY
CID000814
Gold
Japan Mint
JAPAN
CID000823
Gold
Jiangxi Copper Co., Ltd.
CHINA
CID000855
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
RUSSIAN FEDERATION
CID000927
Gold
JSC Uralelectromed
RUSSIAN FEDERATION
CID000929
Gold
JX Nippon Mining & Metals Co., Ltd.
JAPAN
CID000937




Gold
Kazzinc
KAZAKHSTAN
CID000957
Gold
Kennecott Utah Copper LLC
UNITED STATES OF AMERICA
CID000969
Gold
Kojima Chemicals Co., Ltd.
JAPAN
CID000981
Gold
Korea Zinc Co., Ltd.
KOREA, REPUBLIC OF
CID002605
Gold
Kyrgyzaltyn JSC
KYRGYZSTAN
CID001029
Gold
LS-NIKKO Copper Inc.
KOREA, REPUBLIC OF
CID001078
Gold
Materion
UNITED STATES OF AMERICA
CID001113
Gold
Matsuda Sangyo Co., Ltd.
JAPAN
CID001119
Gold
Metalor Technologies S.A.
SWITZERLAND
CID001153
Gold
Metalor Technologies (Hong Kong) Ltd.
CHINA
CID001149
Gold
Metalor Technologies (Singapore) Pte., Ltd.
SINGAPORE
CID001152
Gold
Metalor Technologies (Suzhou) Ltd.
CHINA
CID001147
Gold
Metalor USA Refining Corporation
UNITED STATES OF AMERICA
CID001157
Gold
Metalurgica Met-Mex Penoles S.A. De C.V.
MEXICO
CID001161
Gold
Mitsubishi Materials Corporation
JAPAN
CID001188
Gold
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001193
Gold
MMTC-PAMP India Pvt., Ltd.
INDIA
CID002509
Gold
Moscow Special Alloys Processing Plant
RUSSIAN FEDERATION
CID001204
Gold
Nadir Metal Rafineri San. Ve Tic. A.S.
TURKEY
CID001220
Gold
Nihon Material Co., Ltd.
JAPAN
CID001259
Gold
Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH
AUSTRIA
CID002779
Gold
Ohura Precious Metal Industry Co., Ltd.
JAPAN
CID001325
Gold
OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)
RUSSIAN FEDERATION
CID001326
Gold
OJSC Novosibirsk Refinery
RUSSIAN FEDERATION
CID000493
Gold
PAMP S.A.
SWITZERLAND
CID001352
Gold
Prioksky Plant of Non-Ferrous Metals
RUSSIAN FEDERATION
CID001386
Gold
PT Aneka Tambang (Persero) Tbk
INDONESIA
CID001397
Gold
PX Precinox S.A.
SWITZERLAND
CID001498
Gold
Rand Refinery (Pty) Ltd.
SOUTH AFRICA
CID001512
Gold
Republic Metals Corporation
UNITED STATES OF AMERICA
CID002510
Gold
Royal Canadian Mint
CANADA
CID001534
Gold
Samduck Precious Metals
KOREA, REPUBLIC OF
CID001555
Gold
SAXONIA Edelmetalle GmbH
GERMANY
CID002777
Gold
Schone Edelmetaal B.V.
NETHERLANDS
CID001573
Gold
SEMPSA Joyeria Plateria S.A.
SPAIN
CID001585
Gold
Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
CHINA
CID001622
Gold
Sichuan Tianze Precious Metals Co., Ltd.
CHINA
CID001736
Gold
Singway Technology Co., Ltd.
TAIWAN, PROVINCE OF CHINA
CID002516
Gold
SOE Shyolkovsky Factory of Secondary Precious Metals
RUSSIAN FEDERATION
CID001756




Gold
Solar Applied Materials Technology Corp.
TAIWAN, PROVINCE OF CHINA
CID001761
Gold
Sumitomo Metal Mining Co., Ltd.
JAPAN
CID001798
Gold
T.C.A S.p.A
ITALY
CID002580
Gold
Tanaka Kikinzoku Kogyo K.K.
JAPAN
CID001875
Gold
Tokuriki Honten Co., Ltd.
JAPAN
CID001938
Gold
Torecom
KOREA, REPUBLIC OF
CID001955
Gold
Umicore Brasil Ltda.
BRAZIL
CID001977
Gold
Umicore S.A. Business Unit Precious Metals Refining
BELGIUM
CID001980
Gold
Umicore Precious Metals Thailand
THAILAND
CID002314
Gold
United Precious Metal Refining, Inc.
UNITED STATES OF AMERICA
CID001993
Gold
Valcambi S.A.
SWITZERLAND
CID002003
Gold
Western Australian Mint (T/a The Perth Mint)
AUSTRALIA
CID002030
Gold
WIELAND Edelmetalle GmbH
GERMANY
CID002778
Gold
Yamakin Co., Ltd.
JAPAN
CID002100
Gold
Yokohama Metal Co., Ltd.
JAPAN
CID002129
Gold
Zhongyuan Gold Smelter of Zhongjin Gold Corporation
CHINA
CID002224
Tin
Alpha
UNITED STATES OF AMERICA
CID000292
Tin
PT Bukit Timah
INDONESIA
CID001428
Tin
PT Refined Bangka Tin
INDONESIA
CID001460
Tin
Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
CHINA
CID000228
Tin
China Tin Group Co., Ltd.
CHINA
CID001070
Tin
Yunnan Tin Company Limited
CHINA
CID002180
Tin
CV Ayi Jaya
INDONESIA
CID002570
Tin
CV Dua Sekawan
INDONESIA
CID002592
Tin
CV Gita Pesona
INDONESIA
CID000306
Tin
PT Premium Tin Indonesia
INDONESIA
CID000313
Tin
CV Tiga Sekawan
INDONESIA
CID002593
Tin
CV United Smelting
INDONESIA
CID000315
Tin
CV Venus Inti Perkasa
INDONESIA
CID002455
Tin
Dowa
JAPAN
CID000402
Tin
EM Vinto
BOLIVIA (PLURINATIONAL STATE OF)
CID000438
Tin
Fenix Metals
POLAND
CID000468
Tin
Gejiu Fengming Metallurgy Chemical Plant
CHINA
CID002848
Tin
Gejiu Jinye Mineral Company
CHINA
CID002859
Tin
Gejiu Kai Meng Industry and Trade LLC
CHINA
CID000942
Tin
Gejiu Non-Ferrous Metal Processing Co., Ltd.
CHINA
CID000538
Tin
Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
CHINA
CID001908
Tin
Guangdong Hanhe Non-Ferrous Metal Co., Ltd.
CHINA
CID003116
Tin
Guanyang Guida Nonferrous Metal Smelting Plant
CHINA
CID002849
Tin
HuiChang Hill Tin Industry Co., Ltd.
CHINA
CID002844
Tin
Huichang Jinshunda Tin Co., Ltd.
CHINA
CID000760
Tin
PT Timah (Persero) Tbk Mentok
INDONESIA
CID001482
Tin
Jiangxi Ketai Advanced Material Co., Ltd.
CHINA
CID000244




Tin
PT Timah (Persero) Tbk Kundur
INDONESIA
CID001477
Tin
Magnu's Minerais Metais e Ligas Ltda.
BRAZIL
CID002468
Tin
Malaysia Smelting Corporation (MSC)
MALAYSIA
CID001105
Tin
Melt Metais e Ligas S.A.
BRAZIL
CID002500
Tin
Metallic Resources, Inc.
UNITED STATES OF AMERICA
CID001142
Tin
Metallo Belgium N.V.
BELGIUM
CID002773
Tin
Metallo Spain S.L.U.
SPAIN
CID002774
Tin
Mineracao Taboca S.A.
BRAZIL
CID001173
Tin
Minsur
PERU
CID001182
Tin
Mitsubishi Materials Corporation
JAPAN
CID001191
Tin
Jiangxi New Nanshan Technology Ltd.
CHINA
CID001231
Tin
O.M. Manufacturing (Thailand) Co., Ltd.
THAILAND
CID001314
Tin
O.M. Manufacturing Philippines, Inc.
PHILIPPINES
CID002517
Tin
Operaciones Metalurgical S.A.
BOLIVIA (PLURINATIONAL STATE OF)
CID001337
Tin
PT Aries Kencana Sejahtera
INDONESIA
CID000309
Tin
PT Artha Cipta Langgeng
INDONESIA
CID001399
Tin
PT ATD Makmur Mandiri Jaya
INDONESIA
CID002503
Tin
PT Babel Inti Perkasa
INDONESIA
CID001402
Tin
PT Bangka Prima Tin
INDONESIA
CID002776
Tin
PT Bangka Tin Industry
INDONESIA
CID001419
Tin
PT Belitung Industri Sejahtera
INDONESIA
CID001421
Tin
PT DS Jaya Abadi
INDONESIA
CID001434
Tin
PT Eunindo Usaha Mandiri
INDONESIA
CID001438
Tin
PT Inti Stania Prima
INDONESIA
CID002530
Tin
PT Karimun Mining
INDONESIA
CID001448
Tin
PT Kijang Jaya Mandiri
INDONESIA
CID002829
Tin
PT Lautan Harmonis Sejahtera
INDONESIA
CID002870
Tin
PT Menara Cipta Mulia
INDONESIA
CID002835
Tin
PT Mitra Stania Prima
INDONESIA
CID001453
Tin
PT Panca Mega Persada
INDONESIA
CID001457
Tin
PT Prima Timah Utama
INDONESIA
CID001458
Tin
PT Sariwiguna Binasentosa
INDONESIA
CID001463
Tin
PT Stanindo Inti Perkasa
INDONESIA
CID001468
Tin
PT Sukses Inti Makmur
INDONESIA
CID002816
Tin
PT Sumber Jaya Indah
INDONESIA
CID001471
Tin
PT Tinindo Inter Nusa
INDONESIA
CID001490
Tin
PT Tommy Utama
INDONESIA
CID001493
Tin
Resind Industria e Comercio Ltda.
BRAZIL
CID002706
Tin
Rui Da Hung
TAIWAN, PROVINCE OF CHINA
CID001539
Tin
Soft Metais Ltda.
BRAZIL
CID001758
Tin
Thaisarco
THAILAND
CID001898
Tin
White Solder Metalurgia e Mineracao Ltda.
BRAZIL
CID002036
Tin
Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
CHINA
CID002158
Tungsten
A.L.M.T. TUNGSTEN Corp.
JAPAN
CID000004
Tungsten
ACL Metais Eireli
BRAZIL
CID002833
Tungsten
Asia Tungsten Products Vietnam Ltd.
VIET NAM
CID002502
Tungsten
Chenzhou Diamond Tungsten Products Co., Ltd.
CHINA
CID002513




Tungsten
Chongyi Zhangyuan Tungsten Co., Ltd.
CHINA
CID000258
Tungsten
Fujian Jinxin Tungsten Co., Ltd.
CHINA
CID000499
Tungsten
Ganzhou Huaxing Tungsten Products Co., Ltd.
CHINA
CID000875
Tungsten
Ganzhou Jiangwu Ferrotungsten Co., Ltd.
CHINA
CID002315
Tungsten
Ganzhou Seadragon W & Mo Co., Ltd.
CHINA
CID002494
Tungsten
Global Tungsten & Powders Corp.
UNITED STATES OF AMERICA
CID000568
Tungsten
Guangdong Xianglu Tungsten Co., Ltd.
CHINA
CID000218
Tungsten
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002542
Tungsten
H.C. Starck Tungsten GmbH
GERMANY
CID002541
Tungsten
Hunan Chenzhou Mining Co., Ltd.
CHINA
CID000766
Tungsten
Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji
CHINA
CID002579
Tungsten
Hunan Chunchang Nonferrous Metals Co., Ltd.
CHINA
CID000769
Tungsten
Hydrometallurg, JSC
RUSSIAN FEDERATION
CID002649
Tungsten
Japan New Metals Co., Ltd.
JAPAN
CID000825
Tungsten
Jiangwu H.C. Starck Tungsten Products Co., Ltd.
CHINA
CID002551
Tungsten
Jiangxi Gan Bei Tungsten Co., Ltd.
CHINA
CID002321
Tungsten
Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
CHINA
CID002318
Tungsten
Jiangxi Xinsheng Tungsten Industry Co., Ltd.
CHINA
CID002317
Tungsten
Jiangxi Yaosheng Tungsten Co., Ltd.
CHINA
CID002316
Tungsten
Kennametal Fallon
UNITED STATES OF AMERICA
CID000966
Tungsten
Kennametal Huntsville
UNITED STATES OF AMERICA
CID000105
Tungsten
Malipo Haiyu Tungsten Co., Ltd.
CHINA
CID002319
Tungsten
Niagara Refining LLC
UNITED STATES OF AMERICA
CID002589
Tungsten
Nui Phao H.C. Starck Tungsten Chemicals Manufacturing LLC
VIET NAM
CID002543
Tungsten
Tejing (Vietnam) Tungsten Co., Ltd.
VIET NAM
CID001889
Tungsten
Vietnam Youngsun Tungsten Industry Co., Ltd.
VIET NAM
CID002011
Tungsten
Wolfram Bergbau und Hutten AG
AUSTRIA
CID002044
Tungsten
Xiamen Tungsten (H.C.) Co., Ltd.
CHINA
CID002320
Tungsten
Xiamen Tungsten Co., Ltd.
CHINA
CID002082
Tungsten
Xinhai Rendan Shaoguan Tungsten Co., Ltd.
CHINA
CID002095
Tantalum
H.C. Starck Co., Ltd.
THAILAND
CID002544
Tantalum
H.C. Starck Tantalum and Niobium GmbH
GERMANY
CID002545
Tantalum
H.C. Starck Hermsdorf GmbH
GERMANY
CID002547
Tantalum
H.C. Starck Inc.
UNITED STATES OF AMERICA
CID002548
Tantalum
H.C. Starck Ltd.
JAPAN
CID002549
Tantalum
H.C. Starck Smelting GmbH & Co. KG
GERMANY
CID002550
Tantalum
Mitsui Mining and Smelting Co., Ltd.
JAPAN
CID001192
Tantalum
Ningxia Orient Tantalum Industry Co., Ltd.
CHINA
CID001277
Tantalum
Ulba Metallurgical Plant JSC
KAZAKHSTAN
CID001969
Tantalum
Global Advanced Metals Boyertown
UNITED STATES OF AMERICA
CID002557
Tantalum
F&X Electro-Materials Ltd.
CHINA
CID000460
Tantalum
Global Advanced Metals Aizu
JAPAN
CID002558
Tantalum
Changsha South Tantalum Niobium Co., Ltd.
CHINA
CID000211




Tantalum
Guangdong Rising Rare Metals-EO Materials Ltd.
CHINA
CID000291
Tantalum
Exotech Inc.
UNITED STATES OF AMERICA
CID000456
Tantalum
JiuJiang JinXin Nonferrous Metals Co., Ltd.
CHINA
CID000914
Tantalum
Jiujiang Tanbre Co., Ltd.
CHINA
CID000917
Tantalum
D Block Metals, LLC
UNITED STATES OF AMERICA
CID002504
Tantalum
Hengyang King Xing Lifeng New Materials Co., Ltd.
CHINA
CID002492
Tungsten
Moliren Ltd.
RUSSIAN FEDERATION
CID002845
Tungsten
Philippine Chuangxin Industrial Co., Inc.
PHILIPPINES
CID002827
Tungsten
South-East Nonferrous Metal Company Limited of Hengyang City
CHINA
CID002815
Tungsten
Unecha Refractory metals plant
RUSSIAN FEDERATION
CID002724
Tungsten
Woltech Korea Co., Ltd.
KOREA, REPUBLIC OF
CID002843
Tungsten
Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.
CHINA
CID002830


IDT Due Diligence Framework
IDT has exercised due diligence on the source and chain of custody of our 3TG Minerals to identify minerals originating from the Covered Countries that are not from scrap or recycled materials. IDT’s due diligence process has been designed and implemented based on the framework set forth by the OECD in its due diligence guidance materials. Our 3TG Minerals due diligence process in calendar year 2017 included each of the five OECD-recommended steps:
1.
Establishment of Strong Company Management System.
IDT has established a management system for complying with the applicable rules and industry guidelines. Overseeing this system is the Conflict Minerals Compliance Committee which includes representatives from Legal, Quality, Manufacturing, Environmental-Health & Safety, and Supply Chain/Procurement. Supplier outreach and data collection is handled by the subject-matter expert within the Quality organization, who receives significant support from numerous cross-functional team members. The Quality team leader also is responsible for implementation and oversight of the due diligence process. He is supported by the Legal Department, and the Supply Chain and Procurement teams in his efforts to ensure timely gathering of customer responses and other supply chain data, and in performing his validation and documentation responsibilities.
2.
Identify and assess risks in the supply chain.
IDT has made reasonable efforts to identify suppliers that supply products that may potentially contain 3TG Minerals by conducting a supply chain survey using the EICC and GESI Conflict Minerals Reporting Template, requesting suppliers to identify smelters and refiners and countries of origin of the 3TG Minerals in products they produce or supply for/to IDT; following up with suppliers that do not respond to our request to complete the template until they do; comparing smelters and refiners identified by the supply chain survey against the list of facilities that have received a “conflict free” designation from the CFS program; and maintaining documentation of reasonable efforts we have made to complete these risk assessment steps. Responses also are reviewed and flagged for further follow up if they raise any concerns, and key risks in the supply chain are identified and addressed so that such concerns and risks can be eliminated.
3.
Design and implement a strategy to respond to identified risks.
IDT has and will continue to make reasonable efforts to encourage suppliers who are sourcing from non-conflict free smelters to use conflict free smelters and refiners (as identified in the CFS program and other industry-developed third-party audit mechanisms). If a supplier fails to or is unable to remedy the risks identified by our risk assessment, IDT makes a determination on whether the supplier should be rejected and replaced with an alternate supplier. Factors that will be considered in such a decision will include: i) dedication to continued efforts to become compliant; ii) whether an alternative supplier is available; iii) cost of using a new supplier; iv) existing competitive bids; v) whether the supplier is a single source; vi) other relevant risk factors or potential risk factors. In the event IDT were to continue use of a non-compliant supplier due to inherent limitations of the supply chain, IDT would use reasonable efforts to require supplier to generate a correction plan and to work with CFS compliant smelters and refiners.
4.
Encourage independent, third-party audits of smelters’ and refiners’ due diligence practices.




IDT does not have a direct relationship with any 3TG Mineral smelters or refiners. Thus, IDT is not able to perform a direct audit of the entities that put 3TG Minerals into our supply chain. However, IDT does rely upon industry efforts, including EICC and CFSI efforts to influence smelters and refiners to undergo audits and become certified through CFSI’s certification program. We rely upon summary audit reports on compliance status for smelters generated by the CFS program to validate the responses received from suppliers to our RCOI process and address red flags identified in Step 2, above. We believe our efforts meet the diligence requirements set out in the OECD guidance.
5.
Report annually on supply chain due diligence.
IDT files its Form SD and Conflict Minerals Report annually, in compliance with the Act and the Rule. In addition to this annual report, IDT publishes its conflict free sourcing policy statement on the IDT.com website at:

http://www.idt.com/about/corporate-responsibility-citizenship/conflict-free-metals-policy

Inherent Limitations on Due Diligence Measures
As a downstream purchaser of 3TG Minerals, IDT’s due diligence measures can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the 3TG Minerals in or used to produce our products. Our due diligence processes necessarily rely on the data supplied by our direct suppliers. Those direct suppliers, in turn, rely on similar information provided within their supply chains to identify the original sources of the 3TG Minerals. In addition, IDT relies on information collected and provided by independent third-party audit programs.

Results of Due Diligence Measures Taken
Due to the level of complexity of our products and the respective supply chains, it will take additional time and resources for a number of our suppliers to verify the source mines and country of origin of all of the 3TG Minerals used by their smelters. We are committed to continuing the use of our supply chain due diligence processes, leveraging the industry standard CFS program, and updating our supplier RCOI information on an ongoing basis as we continue to develop additional transparency into our supply chain.

CONFLICT MINERALS REPORT
The Conflict Minerals Report (“CMR”) for calendar year ended December 31, 2017 is filed with the SEC as Exhibit 1.02 to Form SD and is available at

http://ir.idt.com/sec.cfm?DocType=&DocTypeExclude=&SortOrder=FilingDate%20Descending&Year=&Pagenum=4&FormatFilter=