ther is a dochtml May 28, 2021 - EX-1.01 - SD: Specialized Disclosure Report filed pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to the use of conflict minerals (Rule 13p-1) | Microchip Technology Incorporated (MCHP)

Form: SD

Specialized Disclosure Report filed pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act relating to the use of conflict minerals (Rule 13p-1)

May 28, 2021

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EXHIBIT 1.01

CONFLICT MINERALS REPORT
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MICROCHIP TECHNOLOGY INCORPORATED
In Accord with Rule 13p-1 Under the Securities Exchange Act of 1934

This report for the year ended December 31, 2020, is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 ("Rule 13p-1"). Rule 13p-1 was adopted by the United States Securities and Exchange Commission ("SEC") to implement reporting and disclosure requirements related to conflict minerals as directed by Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 ("Dodd-Frank"). Rule 13p-1 imposes certain reporting obligations on SEC registrants whose products contain conflict minerals necessary to the functionality or production of their products. Conflict Minerals are defined by Rule 13p-1 as gold, cassiterite, columbite-tantalite, wolframite, and their derivatives, which are limited to tin, tantalum, and tungsten.

If a registrant has reason to believe that any conflict minerals in their supply chain may have originated in the Democratic Republic of the Congo or an adjoining country ("Covered Countries"), or if they are unable to determine the country of origin of conflict minerals or that their products are manufactured entirely from recycled and scrap sources, then the issuer must exercise due diligence on the source and chain of custody of the conflict minerals. The registrant must annually submit a Conflict Minerals Report ("CMR") to the SEC that includes a description of those due diligence measures. This report is Microchip Technology Incorporated's CMR for the reporting calendar year ended December 31, 2020.

This report is not audited, as Rule 13p-1 and current SEC guidance provide that if the registrant is not declaring products as "DRC Conflict Free," the CMR is not subject to an independent private sector audit ("IPSA").

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1.    COMPANY OVERVIEW
MICROCHIP TECHNOLOGY INCORPORATED develops, manufactures, contracts to manufacture and sells specialized semiconductor products used by its customers in a wide variety of embedded control applications. Microchip Technology Incorporated was incorporated in Delaware in 1989. In this CMR, "we," "us," and "our" each refers to Microchip Technology Incorporated and its subsidiaries ("Microchip"). Our executive offices are located at 2355 West Chandler Boulevard, Chandler, Arizona 85224-6199 and our telephone number is (480) 792-7200.

Our Internet address is www.microchip.com. This CMR will be posted on our website with our other SEC filings under About Us/Investor Relations as soon as reasonably practicable after it is electronically filed with the SEC. All of our SEC filings are available on our website free of charge. Additionally, this CMR will be posted on our designated Responsible Minerals Sourcing webpage at the internet address
https://www.microchip.com/en-us/about/corporate-responsibility/responsible-minerals-sourcing.

The information on our website is not incorporated into this CMR.

1.1    Microchip Products
Microchip Technology Incorporated is a leading provider of smart, connected and secure embedded control solutions. Its easy-to-use development tools and comprehensive product portfolio enable customers to create optimal designs, which reduce risk while lowering total system cost and time to market. The company's solutions serve more than 120,000 customers across the industrial, automotive, consumer, aerospace and defense, communications and computing markets. Headquartered in Chandler, Arizona, Microchip offers outstanding technical support along with dependable delivery and quality.

A more detailed discussion of our product categories and the products relating to each category for calendar year 2020 are contained in our Annual Reports and SEC filings available on: https://www.microchip.com/documentlisting/annual-reports.

For the purposes of this report, Microchip’s products are further delineated in the table below separating integrated circuits from all other types of products.

All references to “Microchip” products hereafter include Microchip and all subsidiaries’ products in Categories A and B that were manufactured by Microchip or its subsidiaries, or contracted by Microchip or its subsidiaries to be manufactured, and within the scope of Rule 13p-1 ("Microchip products") unless specifically attributed to Microchip

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or a specific subsidiary (e.g. "Microchip Category A products" vs. "subsidiary Category A products").
Conflict Minerals Disclosure Category Conflict Minerals Product Description
A
Integrated circuits including touch screen controller ICs (e.g., PIC® Microcontrollers, dsPIC® Digital Signal Controllers, touch and gesture sensing solutions, analog and interface, RF front-end products, wireless audio, USB and wireless solutions, embedded security products, memory products, medical electronics, LED drivers, printer/EL drivers, telecommunications, general industrial.) Integrated circuits including field programmable gate arrays ("FPGAs"),
 application-specific integrated circuits ("ASICs"), Power-over-Ethernet integrated circuits ("ICs").
B RF modules and touch screen controller boards
System-in-Package (SiP) hybrid modules
System on chip solutions ("SoCs"), Power management products; timing and synchronization devices and precise time solutions, voice processing devices; radio frequency ("RF") solutions; discrete components; enterprise storage and communication solution products, midspans, security technologies and scalable anti-tamper products; Ethernet solutions; as well as custom design capabilities and services.
R&D application development printed circuit boards and system kits

We conducted an analysis of Microchip products and found that small quantities of tin, tantalum, tungsten and/or gold ("3TG"), necessary to their functionality or production, are found in substantially all Microchip products (Categories A, and B).

1.2    Conflict Minerals Report
For all product categories, we have been unable to conclusively determine the origin of the 3TG that our products contain, or to conclusively determine to what extent they come from recycled or scrap sources; the facilities used to process them; their country of origin; or their mine or location of origin. Our suppliers reported at broad levels, often at the company or large product family level. None of our suppliers identified which entities sourced Microchip products and none of our suppliers reported that all entities identified on their Responsible Minerals Initiative Conflict Minerals Reporting Template ("RMI-CMRT") sourced Microchip products. This report describes our Reasonable Country of Origin Inquiry (“RCOI”) for context, the due diligence measures we took on the 3TG source and chain of custody, a description of the products manufactured or contracted to be manufactured for which we controlled the design and specified or approved the utilized materials, the results of our due diligence efforts, and expected risk assessment and mitigation steps.


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1.3    Conflict Minerals Policy
Microchip has adopted a conflict minerals policy. Our publicly available policy is on our company website at https://www.microchip.com/en-us/about/corporate-responsibility/responsible-minerals-sourcing.

2.    Microchip’s Reasonable Country of Origin Inquiry (RCOI) Results
Beginning in 2020, Microchip contracted an industry leading third-party provider help with conducting our annual RCOIs for our respective supply chains.

2.1    Category A Products
Beginning in July 2020, Microchip sent the RMI-CMRT with a set of educational and instructional documents, requesting the completion of the RMI CMRT to well-defined raw materials suppliers and its contract manufacturers for Category A products.

We reviewed the responses against criteria developed to determine valid responses and to identify candidates for subsequent inquiry ("Response Criteria"). For Microchip Category A inquiries, we received responses that we considered valid, including some requiring subsequent inquiry, from all first-tier suppliers.

TABLE 1
    Category A Products, Smelter Metrics - 2361 Total Smelters    
Metal Smelters recognized by the RMI RMAP to be Conformant with their responsible minerals sourcing protocols Smelters actively participating in sourcing audits by RMI RMAP, TI-CMC, LBMA, or similar Smelters that use 100% scrap or recycled sources Smelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered Countries
Tantalum 37 of 37 0 of 37 6 of 37 19 of 37
Tin 53 of 53 0 of 53 9 of 53 3 of 53
Tungsten 38 of 38 0 of 38 2 of 38 5 of 38
Gold 107 of 108 1 of 108 43 of 108 6 of 108

All smelters for Category A products known to source from the Covered Countries, or for which there is reason to believe may source from the Covered Countries, are recognized as Conformant with RMI Responsible Minerals Assurance Process (RMAP) responsible mineral sourcing protocols and are listed on the RMI's "Conformant" smelter list.

1 The total number of reported smelters represents verified legitimate smelters or refiners of 3TGs, that have been reported by at least one of your suppliers in our 2020 RCOI. Data is provided by our third-party due diligence consultants.

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2.2    Category B Products
For Category B products, Microchip started an RCOI in July 2020. Having identified and queried the printed circuit board manufacturers and the subcontract manufacturers’ unique materials previously, we successfully expanded our inquiry of discrete component manufacturers for all Categories and manufacturers of peripheral equipment.
TABLE 2
Category B Products, Smelter Metrics - 3322 Total Smelters
Metal Smelters recognized by the RMI RMAP to be Conformant with their responsible minerals sourcing protocols Smelters actively participating in sourcing audits by RMI RMAP, TI-CMC, LBMA, or similar Smelters not actively participating in sourcing audits by RMI RMAP, TI- CMC, LBMA, or similar Smelters that use 100% scrap or recycled sources Smelters known to source from the Covered Countries or for which there is reason to believe may source from the Covered Countries
Tantalum 37 of 37 0 of 37 0 of 37 6 of 37 19 of 37
Tin 54 of 77 11 of 77 12 of 77 12 of 77 3 of 77
Tungsten 39 of 47 5 of 47 3 of 47 6 of 47 5 of 47
Gold 108 of 171 6 of 171 57 of 171 55 of 171 16 of 171

33 of the 43 smelters for Category B products that are known to source from the Covered Countries, or for which there is a reason to believe may source from the Covered Countries are recognized as Conformant with RMI Responsible Minerals Assurance Process (RMAP). The remaining ten smelters that are known to source from the Covered Countries, or for which there is a reason to believe may source from the Covered Countries, are not recognized as Conformant with the RMI RMAP, thus additional due diligence was conducted. For more information on these eight smelters, please go to section 3.3.1 “Category B Identified Risks.”

3.    MICROCHIP DUE DILIGENCE PROCESS

3.1    Design of Due Diligence
We made a good faith effort in the reporting year to work within the framework of the Organization for Economic Co-Operation and Development’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, OECD Publishing ("OECD Guidance") and related Supplements for 3TG, as it relates to our position in the supply chain as a “downstream company.”

3.2    OECD Step 1: Strong Company Management Systems
Microchip operates under a set of Guiding Values and a Code of Business Conduct & Ethics that form the foundation of management systems at Microchip. Continuing through the reporting year, Microchip expressed its concern and
2 The total number of reported smelters represents verified legitimate smelters or refiners of 3TGs, that have been reported by at least one of your suppliers in our 2020 RCOI. Data is provided by our third-party due diligence consultants.

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commitment regarding conflict minerals sourcing from the DRC and Covered Countries in a publicly available policy statement on conflict minerals as outlined in Section 1.3 above.

In addition, Microchip communicates our concern and commitment regarding conflict minerals sourcing from the DRC and Covered Countries in our Terms and Conditions of Purchase that accompanies our order acknowledgments.

3.2.1    Internal Team
Continuing through the reporting year, Microchip's management system for conflict minerals included a team of corporate representatives from relevant functions, including corporate social responsibility, legal, manufacturing, corporate environmental services, product environmental, supply management, and risk management. The team is sponsored by Microchip's Sr. VP of Backend Operations, and senior management was briefed about the results of due diligence efforts, including minerals sourcing risks.

The conflict minerals team is responsible for implementing the conflict minerals compliance strategy, including formalizing conflict minerals due diligence practices, developing supplier risk assessment criteria and responses to risk. The team was led by the Senior Manager, Compliance-Trade & Corporate Social Responsibility who acted as the conflict minerals program manager.

3.2.2    Supply Chain Control Systems
To encourage the establishment of a system of controls and transparency over the mineral supply, we participate in the Responsible Minerals Initiative ("RMI"). Participation allows Microchip to promote validation programs (such as the RMAP or standards enacted by the London Bullion Market Association (“LBMA”) or the Responsible Jewellery Council (“RJC”)), increase our knowledge of smelters and refiners in the supply chain, understand the scope and process for audit and validation program plans for metal-specific trade organizations, gain insight into which smelters are known to source from the covered countries, and join discussions of emerging practical due diligence experiences. During the reporting year, Microchip engaged two third-party due diligence consultants experienced with smelter sourcing research and with a proven record of smelter engagement. These consultants reviewed smelter data obtained from our 2020 RCOI for Category A products and raw, and smelter data from our 2020 RCOI for Category B products, and then prepared a technical file for each. Mineral sourcing risk, including customer perception of sourcing risk, is presented to Microchip's senior management.

3.2.3    Microchip Supplier Engagement
In Calendar Year 2020 Microchip engaged an industry leading third-party provider to help conduct our supplier engagement. This engagement included training and educational materials, and supplier support.
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Microchip and our third-party provided reviewed responses against criteria designed to determine the number of valid responses ("Response Criteria"), and we followed up with corrections and clarifications as needed.

Microchip’s supplier engagement activities in the reporting year again focused primarily on Category A suppliers. During the reporting year, we requested completion of the RMI CMRT by raw material suppliers and subcontract manufacturers of Category A products. During the reporting year, we received an 100% response rate from suppliers for Category A products.

For Microchip’s Category B products, Microchip continued and expanded its engagement with the second and third-tier discrete component and peripheral equipment suppliers using the RMI CMRT and educational materials. We again encountered circumstances where the manufacturer of the discrete component declined to provide a completed CMRT because we are not their direct customer - our contract manufacturers are their direct customer. Still, the contract manufacturers are not responsible for specifying the discrete components. We have begun to work more closely with our contract manufacturers to bridge this gap. However, hurdles still exist with our discrete component suppliers. During the reporting year, we received a 77% response rate from suppliers for Category B products. This response rate is lower than past years as the COVID-19 pandemic had a deep impact on our third-tier suppliers.

3.2.4    Grievance Mechanism
Microchip has grievance mechanisms whereby employees, suppliers, and others can report suspected non-compliance with legal requirements and suspected non-compliance with Microchip's Code of Business Conduct & Ethics.

Our Code of Business Conduct & Ethics policy (HR-690), Compliance with Laws policy (HR-685), and Reporting Legal Non-Compliance policy (HR-675) include complaint procedures. These policies are publicly available at https://www.microchip.com/about-us/corporate-responsibility/ethics-conduct.

For additional conflict minerals related grievance, Microchip employees and external parties may also submit concerns or information to ConflictMinerals@Microchip.com.

3.2.5    Maintain Records
Microchip has developed a process for collecting and retaining RCOI and due diligence documentation that was directed, controlled, and archived by the conflict minerals team.

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3.3    OECD Step 2: Identification and Assessment of Risk in the Supply Chain
Because of our size, the complexity of our products, and the depth, breadth, and evolution of our supply chain, it can be challenging to identify suppliers upstream from our first tier (direct) suppliers. Accordingly, we identify direct suppliers that supply products to us that may contain conflict minerals. We pursue smelter identification using the RMI CMRT; additionally, Microchip leverages our membership in the RMI as an integral part of our supply chain identification and due diligence and risk assessment processes. Additionally, Microchip uses our third-party due diligence consultants to gain insight into SORs’ sourcing practices, and their internal due diligence procedures to help with risk assessment.

3.3.1    Category B Identified Risks
African Gold Refinery (CID003185), a gold refinery, was reported in our Category B products’ supply chain. This smelter, which is located within the Great Lakes Region of the Covered Countries, presents a credible risk of irresponsible sourcing based upon our third-parties due diligence research. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable.

Kaloti Precious Metals (CID002563), a gold smelter, was reported in our Category B products’ supply chain. It has come to our attention during our third-party due diligence review that there is a reason to believe that this smelter may present a risk of irresponsible sourcing within the Covered Countries as this smelter is in a country without a domestic source of gold. Additionally, Kaloti Precious Metals is not listed on the RMI-RMAP Conformant List for Gold thus has not been audited by any entity accepted by the RMI audit protocols. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable.

Fidelity Printers and Refiners Ltd. (CID002515), a gold refinery, was reported in our Category B products’ supply chain. This smelter may present a risk of irresponsible sourcing within the Covered Countries. Zimbabwe's porous border and known smuggling routes will keep FPR high-risk. Unless it can become RMAP conformant. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain, and where necessary begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable.

Tony Goetz NV (CID002587), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible
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sourcing within the Covered Countries. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable.

Sudan Gold Refining (CID002567), a state-owned gold refinery, was reported in our Category B products’ supply chain. This smelter may present a risk of irresponsible sourcing within the Covered Countries. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like this in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable.

Dijllah Gold Refinery FZC (CID003348), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable.

Fujairah Gold (CID002584), a gold smelter, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable.

Shirpur Gold Refinery Ltd. (CID002588), a gold refinery, was reported in our Category B products’ supply chain. During our third-party due diligence, it has been found that this smelter may present a risk of irresponsible sourcing within the Covered Countries. Microchip will continue to work with its supply chain to educate its suppliers about the risks of having smelters like these in its supply chain and where necessary begin the process of disengaging with the non-cooperating component manufacturers where mitigation appears not feasible or unacceptable.

3.4    OECD Step 3: Strategy to Respond to Identified Risks
We believe that understanding smelter sourcing practices is the best method that can eventually lead to the determination of a product's conflict status. To that end, Microchip is a member of the RMI. We review the lists of
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smelters reported by our supply chain against the RMI RMAP "Conformant" smelter lists, their "active" smelter lists, the TI-CMC "active" smelter list (TI-CMC Category A, Members Progressing Toward RMAP Validation). We use RMI recognized third-party consultants to help identify risks throughout our supply chains. We engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that support conflict in the Covered Countries to seek to establish an acceptable alternative source of 3TG that does not support such conflict. We also engage with smelters reported by our supply chain and for which we can locate viable contact information to voluntarily participate in the RMI RMAP or similar sourcing audit programs leading to recognition by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols.

3.5    OECD Step 4: Carry Out Independent Third-Party Audit of Supply Chain Due Diligence at Identified Points in the Supply Chain
We do not typically have a direct relationship with 3TG smelters and refiners and do not perform direct audits of these entities within our supply chain. Microchip does, however, leverage our third-party due diligence consultants to contact smelters and refiners that we do not have direct relationships with or do not have the ability to contact. Using our third-party due diligence consultants Microchip gains insight into SORs’ sourcing practices, and their internal due diligence procedures. Microchip’s third-party due diligence consultants also encourages non-conformant/non-participating SORs to become conformant by joining the RMI or affiliated groups on our behalf. Additionally, Microchip utilizes and supports the due diligence conducted by programs like the RMI to conduct and coordinate third-party audits to validate 3TG processors sourcing practices.

3.6    OECD Step 5: Report Annual Supply Chain Due Diligence
Microchip’s Due Diligence Review criteria includes a determination of the geographic location, whether there is a known, actively mined, and economically viable reserve of 3TG in the area, whether there is positive evidence of responsible and/or irresponsible sourcing, whether there is contrary evidence of responsible sourcing - all from publicly available sources, the smelters’ websites, the UN Group of Experts, NGOs, the RMI and similar organizations, and from our due diligence consultant’s communication with certain smelters. Please refer to Section 3.3 of this Conflict Minerals Report for the discussion on the steps taken on these ten findings.

As a result of our continued due diligence with suppliers and smelters through Microchip’s third-party due diligence consultant teams, Microchip has determined that approximately 99.6% of our smelters are RMAP conformant, .4% are actively pursuing their conformant status as of the end of our RCOI for our Category A products. These findings are in line with what that we saw at the end of our 2019, 2018, 2017, and 2016 RCOIs.

As a result of our continued due diligence with suppliers and smelters through Microchip’s third-party due diligence consultant teams, Microchip has determined that approximately 71.7% of our smelters are RMAP conformant, 6.6%
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are actively pursuing their conformant status, and 21.7% Not currently enrolled in a validation program as of the end of our RCOI for our Category A products. This is a slight decrease from what that we saw at the end of our 2019, 2018, and 2017.

Based on RCOI information provided by suppliers in Microchip's supply chains, our due diligence efforts, and due diligence provided by our third-party due diligence consultants, the SORs that may have processed the 3TG in Microchip's Category A products include those listed in Table 1. The SORs that may have processed the 3TG in Category B products include those listed in Table 2.

Based on our due diligence efforts, Microchip does not have sufficient information to conclusively determine the countries of origin for the 3TG in our products. Based on the information provided by Microchip's suppliers, our third-party due diligence consultants, the RMI, and others, Microchip believes that the countries of origin for the 3TG in our products include the countries listed in Table 7.

While we identified 60 smelters for Category A products that use exclusively scrap or recycled sources of 3TG, we determined that no correlation can be made to any specific Microchip Category A product type, technology family, or part number. No Microchip Category A product is made exclusively with 3TG solely sourced from scrap or recycled sources.

79 smelters in our Category B products were found to source from scrap or recycled sources of 3TG exclusively, however, we determined that no correlation can be made to any specific Microchip Category B product types, technology families, or part number. No Category B product is made exclusively with 3TG solely sourced from scrap or recycled sources.

Microchip's independent due diligence produced information suggesting 33 reported smelters for Category A products either are known to source from the Covered Countries, or there is reason to believe may or could source from the Covered Countries based upon business relationships. Each of these smelters is recognized by the RMI to be Conformant with the organization’s responsible minerals sourcing protocols and are listed on the RMI RMAP “Conformant” smelter lists.

Microchip's independent due diligence produced information suggesting 43 reported smelters for Category B products either are known to source from the Covered Countries or there is reason to believe may source from the Covered Countries. 33 of these smelters are recognized by the RMI to be “Conformant” with the organization’s responsible minerals sourcing protocols and are listed on the RMI RMAP “Conformant” smelter lists. For the ten
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smelters reported to be in the supply chain for Category B products that were not recognized by the RMI as Conformant with the organization’s responsible minerals sourcing protocols Microchip performed additional due diligence.

In addition to this CMR, we communicate our conflict minerals activities in our annual Sustainability Report and in our conflict minerals sourcing policy, which are available on our company website: https://www.microchip.com/en-us/about/corporate-responsibility/sustainability. The information on our website is not incorporated into this CMR.

3.6.2    Efforts to Determine Mine or Location of Origin
We have determined that participation in RMI, requesting our suppliers complete the RMI CMRT, and retaining third-party due diligence consultants in the reporting year are reasonable ways to determine the mines or countries of origin of the 3TG in our supply chain. Microchip’s Countries of Origin and Reason to Believe Countries of Origin list as provided by the best of our ability based on data provided by our third-party due diligence consultants is listed in Table 7 of this CMR.

3.6.3    Smelters or Refiners
Microchip does not source 3TG directly from the Covered Countries, and Microchip typically does not source 3TG directly from smelters or refiners. The exceptions are gold sputter targets, gold bond wire, and Tin Anode. All gold sputter targets, gold bond wire, and Tin Anode, were purchased from smelters or refiners recognized by the RMI RMAP as Conformant with the organization’s responsible minerals sourcing protocols.

Based on RCOI information provided by suppliers in Microchip’s supply chains, our own due diligence efforts, and due diligence provided by our consultants, the facilities that may have processed the 3TG in Microchip’s Category A products include those listed in Table 1.

4.    STEPS TO BE TAKEN TO MITIGATE RISK

We intend to take the following steps to improve the due diligence conducted to further mitigate risk that the necessary conflict minerals in our products could benefit armed groups in the Covered Countries:
a.Continue to work with the RMI and/or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance and/or other SEC recognized framework.
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b.Consolidate RCOI and due diligence practices and activities into a conflict minerals management system. Continue to retain third-party due diligence consultants experienced with smelter sourcing research and direct smelter engagement.
c.Conduct bi-annual reporting year RCOI for Category A products using the RMI CMRT. Microchip will communicate its expectation that suppliers for Category A products working to remove uncooperative smelters, and smelters that are not actively participating with the RMI RMAP, or similar sourcing programs from the products they provide to Microchip.
d.Conduct annual reporting year RCOI for Category B products using RMI CMRT. Microchip will communicate its expectation that suppliers for Category B products working to remove uncooperative smelters, and smelters that are not actively participating with the RMI RMAP, or similar sourcing programs from the products they provide to Microchip through Microchip's contract manufacturers.
e.Continue to develop supplier engagement strategies that may improve the RCOI response rate for Category B suppliers where Microchip is a second-tier customer or lower.
f.Through our efforts or those of our due diligence consultants, engage with selected smelters to encourage participation with the RMI RMAP responsible minerals sourcing audits.
g.Continue to remove smelters from our Category A supply chain that become uncooperative with the RMI RMAP, or who were at one time, voluntarily participating with the RMI RMAP responsible minerals sourcing audit program or similar programs but who have fallen off the “Conformant” smelter lists unless the RMI places the smelter into its “smelters undergoing extended corrective action” category. Microchip will review the business need for a smelter in this category and may, depending on the cause for removal and the nature and content of affirmative commitments made by the affected smelter, choose to retain the smelter in its supply chain.
h.Engage with direct suppliers found to be supplying us with 3TG from sources that support conflict in any Covered Country to seek to establish an acceptable alternative source of 3TG.

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TABLE 5

Category A Products

Smelters Reported to be in Supply Chain


Metal Smelter Name Smelter Country
Gold 8853 S.p.A. ITALY
Gold Advanced Chemical Company UNITED STATES OF AMERICA
Gold Aida Chemical Industries Co., Ltd. JAPAN
Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY
Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN
Gold AngloGold Ashanti Corrego do Sitio Mineracao BRAZIL
Gold Argor-Heraeus S.A. SWITZERLAND
Gold Asahi Pretec Corp. JAPAN
Gold Asahi Refining Canada Ltd. CANADA
Gold Asahi Refining USA Inc. UNITED STATES OF AMERICA
Gold Asaka Riken Co., Ltd. JAPAN
Gold AU Traders and Refiners SOUTH AFRICA
Gold Aurubis AG GERMANY
Gold Bangalore Refinery INDIA
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES
Gold Boliden AB SWEDEN
Gold C. Hafner GmbH + Co. KG GERMANY
Gold CCR Refinery - Glencore Canada Corporation CANADA
Gold Cendres + Metaux S.A. SWITZERLAND
Gold Chimet S.p.A. ITALY
Gold Chugai Mining JAPAN
Gold DODUCO Contacts and Refining GmbH GERMANY
Gold Dowa JAPAN
Gold DS PRETECH Co., Ltd. KOREA, REPUBLIC OF
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF
Gold Eco-System Recycling Co., Ltd. East Plant JAPAN
Gold Eco-System Recycling Co., Ltd. North Plant JAPAN
Gold Eco-System Recycling Co., Ltd. West Plant JAPAN
Gold Emirates Gold DMCC UNITED ARAB EMIRATES
Gold Geib Refining Corporation UNITED STATES OF AMERICA
Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA
Gold Heimerle + Meule GmbH GERMANY
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Metal Smelter Name Smelter Country
Gold Heraeus Metals Hong Kong Ltd. CHINA
Gold Heraeus Precious Metals GmbH & Co. KG GERMANY
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA
Gold Ishifuku Metal Industry Co., Ltd. JAPAN
Gold Istanbul Gold Refinery TURKEY
Gold Italpreziosi ITALY
Gold Japan Mint JAPAN
Gold Jiangxi Copper Co., Ltd. CHINA
Gold JSC Uralelectromed RUSSIAN FEDERATION
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN
Gold Kazzinc KAZAKHSTAN
Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA
Gold KGHM Polska Miedz Spolka Akcyjna POLAND
Gold Kojima Chemicals Co., Ltd. JAPAN
Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF
Gold Kyrgyzaltyn JSC KYRGYZSTAN
Gold L'Orfebre S.A. ANDORRA
Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF
Gold LT Metal Ltd. KOREA, REPUBLIC OF
Gold Marsam Metals BRAZIL
Gold Materion UNITED STATES OF AMERICA
Gold Matsuda Sangyo Co., Ltd. JAPAN
Gold Metalor Technologies (Hong Kong) Ltd. CHINA
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE
Gold Metalor Technologies (Suzhou) Ltd. CHINA
Gold Metalor Technologies S.A. SWITZERLAND
Gold Metalor USA Refining Corporation UNITED STATES OF AMERICA
Gold Metalurgica Met-Mex Penoles S.A. De C.V. MEXICO
Gold Mitsubishi Materials Corporation JAPAN
Gold Mitsui Mining and Smelting Co., Ltd. JAPAN
Gold MMTC-PAMP India Pvt., Ltd. INDIA
Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION
Gold Nadir Metal Rafineri San. Ve Tic. A.S. TURKEY
Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN
Gold Nihon Material Co., Ltd. JAPAN
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) RUSSIAN FEDERATION
15


Metal Smelter Name Smelter Country
Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION
Gold PAMP S.A. SWITZERLAND
Gold Planta Recuperadora de Metales SpA CHILE
Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION
Gold PT Aneka Tambang (Persero) Tbk INDONESIA
Gold PX Precinox S.A. SWITZERLAND
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA
Gold REMONDIS PMR B.V. NETHERLANDS
Gold Royal Canadian Mint CANADA
Gold SAAMP FRANCE
Gold Safimet S.p.A ITALY
Gold SAFINA A.S. CZECH REPUBLIC
Gold Samduck Precious Metals KOREA, REPUBLIC OF
Gold SAXONIA Edelmetalle GmbH GERMANY
Gold SEMPSA Joyeria Plateria S.A. SPAIN
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA
Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA
Gold Singway Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA
Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION
Gold Solar Applied Materials Technology Corp. TAIWAN, PROVINCE OF CHINA
Gold Sumitomo Metal Mining Co., Ltd. JAPAN
Gold SungEel HiMetal Co., Ltd. KOREA, REPUBLIC OF
Gold T.C.A S.p.A ITALY
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN
Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA
Gold Tokuriki Honten Co., Ltd. JAPAN
Gold TOO Tau-Ken-Altyn KAZAKHSTAN
Gold Torecom KOREA, REPUBLIC OF
Gold Umicore Precious Metals Thailand THAILAND
Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM
Gold United Precious Metal Refining, Inc. UNITED STATES OF AMERICA
Gold Valcambi S.A. SWITZERLAND
Gold Western Australian Mint (T/a The Perth Mint) AUSTRALIA
Gold WIELAND Edelmetalle GmbH GERMANY
Gold Yamakin Co., Ltd. JAPAN
Gold Yokohama Metal Co., Ltd. JAPAN
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA
Tantalum Asaka Riken Co., Ltd. JAPAN
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA
16


Metal Smelter Name Smelter Country
Tantalum D Block Metals, LLC UNITED STATES OF AMERICA
Tantalum Exotech Inc. UNITED STATES OF AMERICA
Tantalum F&X Electro-Materials Ltd. CHINA
Tantalum FIR Metals & Resource Ltd. CHINA
Tantalum Global Advanced Metals Aizu JAPAN
Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA
Tantalum H.C. Starck Co., Ltd. THAILAND
Tantalum H.C. Starck Hermsdorf GmbH GERMANY
Tantalum H.C. Starck Inc. UNITED STATES OF AMERICA
Tantalum H.C. Starck Ltd. JAPAN
Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY
Tantalum H.C. Starck Tantalum and Niobium GmbH GERMANY
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA
Tantalum Jiangxi Tuohong New Raw Material CHINA
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA
Tantalum Jiujiang Tanbre Co., Ltd. CHINA
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA
Tantalum KEMET Blue Metals MEXICO
Tantalum LSM Brasil S.A. BRAZIL
Tantalum Metallurgical Products India Pvt., Ltd. INDIA
Tantalum Mineracao Taboca S.A. BRAZIL
Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA
Tantalum NPM Silmet AS ESTONIA
Tantalum PRG Dooel NORTH MACEDONIA, REPUBLIC OF
Tantalum QuantumClean UNITED STATES OF AMERICA
Tantalum Resind Industria e Comercio Ltda. BRAZIL
Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION
Tantalum Taki Chemical Co., Ltd. JAPAN
Tantalum Telex Metals UNITED STATES OF AMERICA
Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. CHINA
Tin Alpha UNITED STATES OF AMERICA
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA
Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA
Tin China Tin Group Co., Ltd. CHINA
Tin Dowa JAPAN
17


Metal Smelter Name Smelter Country
Tin EM Vinto BOLIVIA (PLURINATIONAL STATE OF)
Tin Fenix Metals POLAND
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA
Tin Gejiu Kai Meng Industry and Trade LLC CHINA
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA
Tin Jiangxi New Nanshan Technology Ltd. CHINA
Tin Luna Smelter, Ltd. RWANDA
Tin Ma'anshan Weitai Tin Co., Ltd. CHINA
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL
Tin Malaysia Smelting Corporation (MSC) MALAYSIA
Tin Melt Metais e Ligas S.A. BRAZIL
Tin Metallic Resources, Inc. UNITED STATES OF AMERICA
Tin Metallo Belgium N.V. BELGIUM
Tin Metallo Spain S.L.U. SPAIN
Tin Mineracao Taboca S.A. BRAZIL
Tin Minsur PERU
Tin Mitsubishi Materials Corporation JAPAN
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES
Tin Operaciones Metalurgicas S.A. BOLIVIA (PLURINATIONAL STATE OF)
Tin PT Artha Cipta Langgeng INDONESIA
Tin PT ATD Makmur Mandiri Jaya INDONESIA
Tin PT Babel Surya Alam Lestari INDONESIA
Tin PT Bangka Serumpun INDONESIA
Tin PT Menara Cipta Mulia INDONESIA
Tin PT Mitra Stania Prima INDONESIA
Tin PT Prima Timah Utama INDONESIA
Tin PT Rajawali Rimba Perkasa INDONESIA
Tin PT Rajehan Ariq INDONESIA
Tin PT Refined Bangka Tin INDONESIA
Tin PT Stanindo Inti Perkasa INDONESIA
Tin PT Timah Tbk Kundur INDONESIA
Tin PT Timah Tbk Mentok INDONESIA
Tin PT Tinindo Inter Nusa INDONESIA
Tin Resind Industria e Comercio Ltda. BRAZIL
Tin Rui Da Hung TAIWAN, PROVINCE OF CHINA
18


Metal Smelter Name Smelter Country
Tin Soft Metais Ltda. BRAZIL
Tin Thai Nguyen Mining and Metallurgy Co., Ltd. VIETNAM
Tin Thaisarco THAILAND
Tin Tin Technology & Refining UNITED STATES OF AMERICA
Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA
Tin Yunnan Tin Company Limited CHINA
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. CHINA
Tungsten A.L.M.T. Corp. JAPAN
Tungsten ACL Metais Eireli BRAZIL
Tungsten Asia Tungsten Products Vietnam Ltd. VIETNAM
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA
Tungsten Fujian Ganmin RareMetal Co., Ltd. CHINA
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA
Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA
Tungsten H.C. Starck Smelting GmbH & Co. KG GERMANY
Tungsten H.C. Starck Tungsten GmbH GERMANY
Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION
Tungsten Japan New Metals Co., Ltd. JAPAN
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA
Tungsten Kennametal Fallon UNITED STATES OF AMERICA
Tungsten Kennametal Huntsville UNITED STATES OF AMERICA
Tungsten KGETS Co., Ltd. KOREA, REPUBLIC OF
Tungsten Lianyou Metals Co., Ltd. TAIWAN, PROVINCE OF CHINA
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA
Tungsten Masan Tungsten Chemical LLC (MTC) VIETNAM
Tungsten Moliren Ltd. RUSSIAN FEDERATION
Tungsten Niagara Refining LLC UNITED STATES OF AMERICA
19


Metal Smelter Name Smelter Country
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION
Tungsten Wolfram Bergbau und Hutten AG AUSTRIA
Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA
Tungsten Xiamen Tungsten Co., Ltd. CHINA
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA
20


TABLE 6

Category B Products

Smelters Reported to be in Supply Chain

Metal Smelter Name Smelter Country
Gold 8853 S.p.A. ITALY
Gold Abington Reldan Metals, LLC UNITED STATES OF AMERICA
Gold Advanced Chemical Company UNITED STATES OF AMERICA
Gold African Gold Refinery UGANDA
Gold Aida Chemical Industries Co., Ltd. JAPAN
Gold Al Etihad Gold Refinery DMCC UNITED ARAB EMIRATES
Gold Alexy Metals UNITED STATES OF AMERICA
Gold Allgemeine Gold-und Silberscheideanstalt A.G. GERMANY
Gold Almalyk Mining and Metallurgical Complex (AMMC) UZBEKISTAN
Gold AngloGold Ashanti Corrego do Sitio Mineracao BRAZIL
Gold Argor-Heraeus S.A. SWITZERLAND
Gold Asahi Pretec Corp. JAPAN
Gold Asahi Refining Canada Ltd. CANADA
Gold Asahi Refining USA Inc. UNITED STATES OF AMERICA
Gold Asaka Riken Co., Ltd. JAPAN
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S. TURKEY
Gold AU Traders and Refiners SOUTH AFRICA
Gold Augmont Enterprises Private Limited INDIA
Gold Aurubis AG GERMANY
Gold Bangalore Refinery INDIA
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) PHILIPPINES
Gold Boliden AB SWEDEN
Gold C. Hafner GmbH + Co. KG GERMANY
Gold C.I Metales Procesados Industriales SAS COLOMBIA
Gold Caridad MEXICO
Gold CCR Refinery - Glencore Canada Corporation CANADA
Gold Cendres + Metaux S.A. SWITZERLAND
Gold CGR Metalloys Pvt Ltd. INDIA
Gold Chimet S.p.A. ITALY
Gold Chugai Mining JAPAN
Gold Daye Non-Ferrous Metals Mining Ltd. CHINA
Gold Degussa Sonne / Mond Goldhandel GmbH GERMANY
Gold Dijllah Gold Refinery FZC UNITED ARAB EMIRATES
Gold DODUCO Contacts and Refining GmbH GERMANY
Gold Dowa JAPAN
21


Metal Smelter Name Smelter Country
Gold DS PRETECH Co., Ltd. KOREA, REPUBLIC OF
Gold DSC (Do Sung Corporation) KOREA, REPUBLIC OF
Gold Eco-System Recycling Co., Ltd. East Plant JAPAN
Gold Eco-System Recycling Co., Ltd. North Plant JAPAN
Gold Eco-System Recycling Co., Ltd. West Plant JAPAN
Gold Emerald Jewel Industry India Limited (Unit 1) INDIA
Gold Emerald Jewel Industry India Limited (Unit 2) INDIA
Gold Emerald Jewel Industry India Limited (Unit 3) INDIA
Gold Emerald Jewel Industry India Limited (Unit 4) INDIA
Gold Emirates Gold DMCC UNITED ARAB EMIRATES
Gold Fidelity Printers and Refiners Ltd. ZIMBABWE
Gold Fujairah Gold FZC UNITED ARAB EMIRATES
Gold GCC Gujrat Gold Centre Pvt. Ltd. INDIA
Gold Geib Refining Corporation UNITED STATES OF AMERICA
Gold Gold Coast Refinery GHANA
Gold Gold Refinery of Zijin Mining Group Co., Ltd. CHINA
Gold Great Wall Precious Metals Co., Ltd. of CBPM CHINA
Gold Guangdong Jinding Gold Limited CHINA
Gold Guoda Safina High-Tech Environmental Refinery Co., Ltd. CHINA
Gold Hangzhou Fuchunjiang Smelting Co., Ltd. CHINA
Gold Heimerle + Meule GmbH GERMANY
Gold Heraeus Metals Hong Kong Ltd. CHINA
Gold Heraeus Precious Metals GmbH & Co. KG GERMANY
Gold Hunan Chenzhou Mining Co., Ltd. CHINA
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. CHINA
Gold HwaSeong CJ CO., LTD. KOREA, REPUBLIC OF
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. CHINA
Gold International Precious Metal Refiners UNITED ARAB EMIRATES
Gold Ishifuku Metal Industry Co., Ltd. JAPAN
Gold Istanbul Gold Refinery TURKEY
Gold Italpreziosi ITALY
Gold JALAN & Company INDIA
Gold Japan Mint JAPAN
Gold Jiangxi Copper Co., Ltd. CHINA
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant RUSSIAN FEDERATION
Gold JSC Uralelectromed RUSSIAN FEDERATION
Gold JX Nippon Mining & Metals Co., Ltd. JAPAN
Gold K.A. Rasmussen NORWAY
Gold Kaloti Precious Metals UNITED ARAB EMIRATES
Gold Kazakhmys Smelting LLC KAZAKHSTAN
22


Metal Smelter Name Smelter Country
Gold Kazzinc KAZAKHSTAN
Gold Kennecott Utah Copper LLC UNITED STATES OF AMERICA
Gold KGHM Polska Miedz Spolka Akcyjna POLAND
Gold Kojima Chemicals Co., Ltd. JAPAN
Gold Korea Zinc Co., Ltd. KOREA, REPUBLIC OF
Gold Kundan Care Products Ltd. INDIA
Gold Kyrgyzaltyn JSC KYRGYZSTAN
Gold Kyshtym Copper-Electrolytic Plant ZAO RUSSIAN FEDERATION
Gold L'azurde Company For Jewelry SAUDI ARABIA
Gold Lingbao Gold Co., Ltd. CHINA
Gold Lingbao Jinyuan Tonghui Refinery Co., Ltd. CHINA
Gold L'Orfebre S.A. ANDORRA
Gold LS-NIKKO Copper Inc. KOREA, REPUBLIC OF
Gold LT Metal Ltd. KOREA, REPUBLIC OF
Gold Luoyang Zijin Yinhui Gold Refinery Co., Ltd. CHINA
Gold Marsam Metals BRAZIL
Gold Materion UNITED STATES OF AMERICA
Gold Matsuda Sangyo Co., Ltd. JAPAN
Gold MD Overseas INDIA
Gold Metal Concentrators SA (Pty) Ltd. SOUTH AFRICA
Gold Metallix Refining Inc. UNITED STATES OF AMERICA
Gold Metalor Technologies (Hong Kong) Ltd. CHINA
Gold Metalor Technologies (Singapore) Pte., Ltd. SINGAPORE
Gold Metalor Technologies (Suzhou) Ltd. CHINA
Gold Metalor Technologies S.A. SWITZERLAND
Gold Metalor USA Refining Corporation UNITED STATES OF AMERICA
Gold Metalurgica Met-Mex Penoles S.A. De C.V. MEXICO
Gold Mitsubishi Materials Corporation JAPAN
Gold Mitsui Mining and Smelting Co., Ltd. JAPAN
Gold MMTC-PAMP India Pvt., Ltd. INDIA
Gold Modeltech Sdn Bhd MALAYSIA
Gold Morris and Watson NEW ZEALAND
Gold Moscow Special Alloys Processing Plant RUSSIAN FEDERATION
Gold Nadir Metal Rafineri San. Ve Tic. A.S. TURKEY
Gold Navoi Mining and Metallurgical Combinat UZBEKISTAN
Gold NH Recytech Company KOREA, REPUBLIC OF
Gold Nihon Material Co., Ltd. JAPAN
Gold Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH AUSTRIA
Gold Ohura Precious Metal Industry Co., Ltd. JAPAN
23


Metal Smelter Name Smelter Country
Gold OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) RUSSIAN FEDERATION
Gold OJSC Novosibirsk Refinery RUSSIAN FEDERATION
Gold PAMP S.A. SWITZERLAND
Gold Pease & Curren UNITED STATES OF AMERICA
Gold Penglai Penggang Gold Industry Co., Ltd. CHINA
Gold Planta Recuperadora de Metales SpA CHILE
Gold Prioksky Plant of Non-Ferrous Metals RUSSIAN FEDERATION
Gold PT Aneka Tambang (Persero) Tbk INDONESIA
Gold PX Precinox S.A. SWITZERLAND
Gold QG Refining, LLC UNITED STATES OF AMERICA
Gold Rand Refinery (Pty) Ltd. SOUTH AFRICA
Gold Refinery of Seemine Gold Co., Ltd. CHINA
Gold REMONDIS PMR B.V. NETHERLANDS
Gold Royal Canadian Mint CANADA
Gold SAAMP FRANCE
Gold Sabin Metal Corp. UNITED STATES OF AMERICA
Gold Safimet S.p.A ITALY
Gold SAFINA A.S. CZECH REPUBLIC
Gold Sai Refinery INDIA
Gold Samduck Precious Metals KOREA, REPUBLIC OF
Gold Samwon Metals Corp. KOREA, REPUBLIC OF
Gold Sancus ZFS (L’Orfebre, SA) COLOMBIA
Gold SAXONIA Edelmetalle GmbH GERMANY
Gold Sellem Industries Ltd. MAURITANIA
Gold SEMPSA Joyeria Plateria S.A. SPAIN
Gold Shandong Humon Smelting Co., Ltd. CHINA
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd. CHINA
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd. CHINA
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd. CHINA
Gold Shirpur Gold Refinery Ltd. INDIA
Gold Sichuan Tianze Precious Metals Co., Ltd. CHINA
Gold Singway Technology Co., Ltd. TAIWAN, PROVINCE OF CHINA
Gold SOE Shyolkovsky Factory of Secondary Precious Metals RUSSIAN FEDERATION
Gold Solar Applied Materials Technology Corp. TAIWAN, PROVINCE OF CHINA
Gold Sovereign Metals INDIA
Gold State Research Institute Center for Physical Sciences and Technology LITHUANIA
Gold Sudan Gold Refinery SUDAN
Gold Sumitomo Metal Mining Co., Ltd. JAPAN
Gold SungEel HiMetal Co., Ltd. KOREA, REPUBLIC OF
24


Metal Smelter Name Smelter Country
Gold T.C.A S.p.A ITALY
Gold Tanaka Kikinzoku Kogyo K.K. JAPAN
Gold The Refinery of Shandong Gold Mining Co., Ltd. CHINA
Gold Tokuriki Honten Co., Ltd. JAPAN
Gold Tongling Nonferrous Metals Group Co., Ltd. CHINA
Gold Tony Goetz NV BELGIUM
Gold TOO Tau-Ken-Altyn KAZAKHSTAN
Gold Torecom KOREA, REPUBLIC OF
Gold Umicore Precious Metals Thailand THAILAND
Gold Umicore S.A. Business Unit Precious Metals Refining BELGIUM
Gold United Precious Metal Refining, Inc. UNITED STATES OF AMERICA
Gold Valcambi S.A. SWITZERLAND
Gold Western Australian Mint (T/a The Perth Mint) AUSTRALIA
Gold WIELAND Edelmetalle GmbH GERMANY
Gold Yamakin Co., Ltd. JAPAN
Gold Yokohama Metal Co., Ltd. JAPAN
Gold Yunnan Copper Industry Co., Ltd. CHINA
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CHINA
Tantalum Asaka Riken Co., Ltd. JAPAN
Tantalum Changsha South Tantalum Niobium Co., Ltd. CHINA
Tantalum D Block Metals, LLC UNITED STATES OF AMERICA
Tantalum Exotech Inc. UNITED STATES OF AMERICA
Tantalum F&X Electro-Materials Ltd. CHINA
Tantalum FIR Metals & Resource Ltd. CHINA
Tantalum Global Advanced Metals Aizu JAPAN
Tantalum Global Advanced Metals Boyertown UNITED STATES OF AMERICA
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CHINA
Tantalum H.C. Starck Co., Ltd. THAILAND
Tantalum H.C. Starck Hermsdorf GmbH GERMANY
Tantalum H.C. Starck Inc. UNITED STATES OF AMERICA
Tantalum H.C. Starck Ltd. JAPAN
Tantalum H.C. Starck Smelting GmbH & Co. KG GERMANY
Tantalum H.C. Starck Tantalum and Niobium GmbH GERMANY
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CHINA
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd. CHINA
Tantalum Jiangxi Tuohong New Raw Material CHINA
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CHINA
Tantalum Jiujiang Tanbre Co., Ltd. CHINA
Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd. CHINA
Tantalum KEMET Blue Metals MEXICO
25


Metal Smelter Name Smelter Country
Tantalum LSM Brasil S.A. BRAZIL
Tantalum Metallurgical Products India Pvt., Ltd. INDIA
Tantalum Mineracao Taboca S.A. BRAZIL
Tantalum Mitsui Mining and Smelting Co., Ltd. JAPAN
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CHINA
Tantalum NPM Silmet AS ESTONIA
Tantalum PRG Dooel NORTH MACEDONIA, REPUBLIC OF
Tantalum QuantumClean UNITED STATES OF AMERICA
Tantalum Resind Industria e Comercio Ltda. BRAZIL
Tantalum Solikamsk Magnesium Works OAO RUSSIAN FEDERATION
Tantalum Taki Chemical Co., Ltd. JAPAN
Tantalum Telex Metals UNITED STATES OF AMERICA
Tantalum Ulba Metallurgical Plant JSC KAZAKHSTAN
Tantalum XinXing HaoRong Electronic Material Co., Ltd. CHINA
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd. CHINA
Tin Alpha UNITED STATES OF AMERICA
Tin An Vinh Joint Stock Mineral Processing Company VIETNAM
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. CHINA
Tin Chifeng Dajingzi Tin Industry Co., Ltd. CHINA
Tin China Tin Group Co., Ltd. CHINA
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda BRAZIL
Tin CRM Synergies SPAIN
Tin CV Ayi Jaya INDONESIA
Tin CV Venus Inti Perkasa INDONESIA
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd. CHINA
Tin Dowa JAPAN
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company VIETNAM
Tin EM Vinto BOLIVIA (PLURINATIONAL STATE OF)
Tin Estanho de Rondonia S.A. BRAZIL
Tin Fenix Metals POLAND
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd. CHINA
Tin Gejiu Fengming Metallurgy Chemical Plant CHINA
Tin Gejiu Kai Meng Industry and Trade LLC CHINA
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd. CHINA
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. CHINA
Tin Gejiu Zili Mining And Metallurgy Co., Ltd. CHINA
Tin Guangdong Hanhe Non-Ferrous Metal Co., Ltd. CHINA
26


Metal Smelter Name Smelter Country
Tin HuiChang Hill Tin Industry Co., Ltd. CHINA
Tin Jiangxi New Nanshan Technology Ltd. CHINA
Tin Luna Smelter, Ltd. RWANDA
Tin Ma'anshan Weitai Tin Co., Ltd. CHINA
Tin Magnu's Minerais Metais e Ligas Ltda. BRAZIL
Tin Malaysia Smelting Corporation (MSC) MALAYSIA
Tin Melt Metais e Ligas S.A. BRAZIL
Tin Metallic Resources, Inc. UNITED STATES OF AMERICA
Tin Metallo Belgium N.V. BELGIUM
Tin Metallo Spain S.L.U. SPAIN
Tin Mineracao Taboca S.A. BRAZIL
Tin Minsur PERU
Tin Mitsubishi Materials Corporation JAPAN
Tin Modeltech Sdn Bhd MALAYSIA
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company VIETNAM
Tin Novosibirsk Processing Plant Ltd. RUSSIAN FEDERATION
Tin O.M. Manufacturing (Thailand) Co., Ltd. THAILAND
Tin O.M. Manufacturing Philippines, Inc. PHILIPPINES
Tin Operaciones Metalurgicas S.A. BOLIVIA (PLURINATIONAL STATE OF)
Tin Pongpipat Company Limited MYANMAR
Tin Precious Minerals and Smelting Limited INDIA
Tin PT Aries Kencana Sejahtera INDONESIA
Tin PT Artha Cipta Langgeng INDONESIA
Tin PT ATD Makmur Mandiri Jaya INDONESIA
Tin PT Babel Inti Perkasa INDONESIA
Tin PT Babel Surya Alam Lestari INDONESIA
Tin PT Bangka Serumpun INDONESIA
Tin PT Bukit Timah INDONESIA
Tin PT Cipta Persada Mulia INDONESIA
Tin PT Lautan Harmonis Sejahtera INDONESIA
Tin PT Menara Cipta Mulia INDONESIA
Tin PT Mitra Stania Prima INDONESIA
Tin PT Mitra Sukses Globalindo INDONESIA
Tin PT Prima Timah Utama INDONESIA
Tin PT Rajawali Rimba Perkasa INDONESIA
Tin PT Rajehan Ariq INDONESIA
Tin PT Refined Bangka Tin INDONESIA
Tin PT Stanindo Inti Perkasa INDONESIA
Tin PT Timah Nusantara INDONESIA
Tin PT Timah Tbk Kundur INDONESIA
27


Metal Smelter Name Smelter Country
Tin PT Timah Tbk Mentok INDONESIA
Tin PT Tinindo Inter Nusa INDONESIA
Tin Resind Industria e Comercio Ltda. BRAZIL
Tin Rui Da Hung TAIWAN, PROVINCE OF CHINA
Tin Soft Metais Ltda. BRAZIL
Tin Super Ligas BRAZIL
Tin Thai Nguyen Mining and Metallurgy Co., Ltd. VIETNAM
Tin Thaisarco THAILAND
Tin Tin Technology & Refining UNITED STATES OF AMERICA
Tin Tuyen Quang Non-Ferrous Metals Joint Stock Company VIETNAM
Tin VQB Mineral and Trading Group JSC VIETNAM
Tin White Solder Metalurgia e Mineracao Ltda. BRAZIL
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd. CHINA
Tin Yunnan Tin Company Limited CHINA
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd. CHINA
Tungsten A.L.M.T. Corp. JAPAN
Tungsten ACL Metais Eireli BRAZIL
Tungsten Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. BRAZIL
Tungsten Artek LLC RUSSIAN FEDERATION
Tungsten Asia Tungsten Products Vietnam Ltd. VIETNAM
Tungsten Chenzhou Diamond Tungsten Products Co., Ltd. CHINA
Tungsten China Molybdenum Co., Ltd. CHINA
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd. CHINA
Tungsten CNMC (Guangxi) PGMA Co., Ltd. CHINA
Tungsten Cronimet Brasil Ltda BRAZIL
Tungsten Fujian Ganmin RareMetal Co., Ltd. CHINA
Tungsten Ganzhou Haichuang Tungsten Co., Ltd. CHINA
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CHINA
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CHINA
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CHINA
Tungsten GEM Co., Ltd. CHINA
Tungsten Global Tungsten & Powders Corp. UNITED STATES OF AMERICA
Tungsten Guangdong Xianglu Tungsten Co., Ltd. CHINA
Tungsten H.C. Starck Smelting GmbH & Co. KG GERMANY
Tungsten H.C. Starck Tungsten GmbH GERMANY
Tungsten Hunan Chenzhou Mining Co., Ltd. CHINA
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CHINA
Tungsten Hydrometallurg, JSC RUSSIAN FEDERATION
Tungsten Japan New Metals Co., Ltd. JAPAN
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd. CHINA
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Metal Smelter Name Smelter Country
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CHINA
Tungsten Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. CHINA
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. CHINA
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd. CHINA
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd. CHINA
Tungsten JSC "Kirovgrad Hard Alloys Plant" RUSSIAN FEDERATION
Tungsten Kennametal Fallon UNITED STATES OF AMERICA
Tungsten Kennametal Huntsville UNITED STATES OF AMERICA
Tungsten KGETS Co., Ltd. KOREA, REPUBLIC OF
Tungsten Lianyou Metals Co., Ltd. TAIWAN, PROVINCE OF CHINA
Tungsten Malipo Haiyu Tungsten Co., Ltd. CHINA
Tungsten Masan Tungsten Chemical LLC (MTC) VIETNAM
Tungsten Moliren Ltd. RUSSIAN FEDERATION
Tungsten Niagara Refining LLC UNITED STATES OF AMERICA
Tungsten NPP Tyazhmetprom LLC RUSSIAN FEDERATION
Tungsten Philippine Chuangxin Industrial Co., Inc. PHILIPPINES
Tungsten Unecha Refractory metals plant RUSSIAN FEDERATION
Tungsten Wolfram Bergbau und Hutten AG AUSTRIA
Tungsten Woltech Korea Co., Ltd. KOREA, REPUBLIC OF
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CHINA
Tungsten Xiamen Tungsten Co., Ltd. CHINA
Tungsten Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. CHINA

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TABLE 7

Countries of Origin4
Argentina Honduras New Zealand Tanzania
Australia India Papua New Guinea Thailand
Bolivia Indonesia Peru Turkey
Brazil Ivory Coast Philippines United States of America
Bulgaria Japan Poland Uzbekistan
Burkina Faso Kazakhstan Portugal Vietnam
Burundi Korea Russia Zambia
Canada Kyrgyzstan Rwanda Zimbabwe
Chile Laos Senegal  
China Mali Sierra Leone  
Colombia Mexico South Africa  
Democratic Republic of the Congo Mongolia Sudan  
Georgia Myanmar Sweden  
Ghana Namibia Tajikistan  




4 Microchip’s Countries of Origin and Reason to Believe Countries of Origin list as provided by the best of our ability based on data provided by our third-party due diligence consultants.

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Caution Concerning Forward-Looking Statements

This Conflict Minerals Report contains forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. Such forward-looking statements include the statements that we plan to engage with any of our suppliers whom we have reason to believe are supplying us with 3TG from sources that support conflict in the DRC, that participation in the Responsible Minerals Initiative allows Microchip to promote validation programs (such as the RMAP or standards enacted by the London Bullion Market Association ("LBMA") or the Responsible Jewellery Council ("RJC")), increase our knowledge of smelters and refiners in the supply chain, understand the scope and process for audit and validation program plans for metal-specific trade organizations, gain insight into which smelters are known to source from the covered countries, and join discussions of emerging practical due diligence experiences; and the steps set forth in Section 4 that we intend to take to improve the due diligence conducted. We also use words such as "believe," "continue," "plan," "expect," "intend" and similar expressions to identify forward-looking statements. All forward-looking statements involve risk and uncertainty. Our actual results could differ materially from the results anticipated in these forward-looking statements for a number of reasons including changes in our supply chain, our ability or inability to obtain an adequate supply of materials from current or alternative suppliers and the cost of such materials, the level of cooperation we receive from our suppliers with respect to our further due diligence, changes in regulations in the U.S. or other countries (including the Covered Countries), or changes in political or economic conditions in the U.S. or other countries (including the Covered Countries). For a detailed discussion of these and other risk factors, please refer to Microchip's filings on forms 10-K and 10-Q. You can obtain copies of Forms 10-K and 10-Q and other relevant documents for free at Microchip's website (www.microchip.com) or the SEC's website (www.sec.gov) or from commercial document retrieval services. Forward-looking statements are based on our current expectations and assumptions, which may not prove to be accurate. Although we believe that the expectations reflected in the forward-looking statements are reasonable, we cannot guarantee future results, levels of activity, performance or achievements. You should not place undue reliance on these forward-looking statements. We disclaim any obligation to update information contained in any forward-looking statement.
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