UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM SD

SPECIALIZED DISCLOSURE REPORT

 

 

LOGITECH INTERNATIONAL S.A.

(Exact name of the registrant as specified in its charter)

 

 

 

Canton of Vaud, Switzerland   0-29174   None

(State or other jurisdiction

of incorporation or organization)

 

(Commission

File Number)

 

(IRS Employer

Identification No.)

 

7700 Gateway Boulevard Newark, California   94560
(Address of principal executive offices)   (Zip code)

Bryan Ko, General Counsel (510) 795-8500

(Name and telephone number, including area code, of the person to contact in connection with this report.)

 

 

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

 

x Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2014.

 

 

 


Introduction:

Logitech International S.A., together with its consolidated subsidiaries, (“Logitech” or the “Company”) is a world leader in products that connect people to the digital experiences they care about. Spanning multiple computing, communication and entertainment platforms, we develop and market innovative hardware and software products that enable or enhance digital navigation, music and video entertainment, gaming, social networking, and audio and video communication over the Internet and home-entertainment control.

Logitech was founded in Switzerland in 1981, and Logitech International S.A. has been the parent holding company of Logitech since 1988. Logitech International S.A. is a Swiss holding company with its registered office in Apples, Switzerland, which conducts its business through subsidiaries in Americas (including North and South America), EMEA (Europe, Middle East, Africa) and Asia Pacific (including, among other countries, China, Taiwan, Japan and Australia). Shares of Logitech International S.A. are listed on both the Nasdaq Global Select Market, under the trading symbol LOGI, and the SIX Swiss Exchange, under the trading symbol LOGN.

Section 1—Conflict Minerals Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

Logitech has adopted a Conflict Minerals Policy which can be found at

http://www.logitech.com/assets/51186/logitech-policy-on-conflict-minerals-jan-2014-signed.pdf

In accordance with the execution of this policy, Logitech has concluded that during 2014:

 

  a) Logitech manufactured and contracted to manufacture products as to which “conflict minerals” (as defined in Section 1, Item 1.01 (d)(3) of Form SD) are necessary to the functionality or production of such products; and

 

  b) Based on its “reasonable country of origin inquiry,” Logitech was unable to obtain sufficient information from the company’s supply chain to make a final determination as to the source of these conflict minerals. Logitech could not establish that the conflict minerals originated from sources in the Democratic Republic of Congo (DRC) or an adjoining country (the “Covered Countries”) as defined by the Rule. Therefore, Logitech has defined its products to be “DRC conflict undeterminable.”

Logitech’s reasonable country of origin inquiry (RCOI) employed a combination of measures outlined below to assess whether the conflict minerals necessary in Logitech products originated from the Covered Countries. Logitech’s primary means of determining country of origin of conflict minerals involved performing a supply-chain survey of direct suppliers through use of the Electronic Industry Citizenship Coalition ® (EICC ®) and The Global e-Sustainability Initiative (GeSI) Conflict Minerals Reporting Template.

We surveyed our direct suppliers, using the template developed by the EICC and GeSI, known as the Conflict-Free Sourcing Initiative (“CFSI”) Reporting Template (“The Template”). The Template was developed to facilitate disclosure and communication of information regarding smelters that sell material to a company’s suppliers. It includes questions regarding a company’s conflict-free policy, engagement with its direct suppliers, and a listing of the smelters the company and its suppliers use. In addition, the template contains questions about the origin of conflict minerals included in their products, as well as supplier due diligence. Written instructions and recorded training illustrating the use of the tool is available on EICC’s website (http://www.eicc.info). The Template is being used by many companies in their due diligence processes related to conflict minerals.


Through the reasonable country of origin inquiry described above, Logitech surveyed all of its direct suppliers (483 suppliers in total). Approximately 95.86% of those suppliers, whom we had reasons to believe may contribute necessary conflict minerals to Logitech Products, provided a response to the supply-chain survey. We reviewed the responses against the criteria designed to evaluate the adequacy of responses. These criteria include, but are not limited to, untimely or incomplete responses as well as inconsistencies within the data reported in the template. We have worked, and continue to work, directly with these suppliers to obtain revised responses.

Through our participation in CFSI, the OECD implementation programs, and request of our suppliers to complete The Template, we have concluded that obtaining information about tin, tungsten, tantalum or gold (“3TG”) smelters and refiners in our supply chain represents the most effective method to determine the mines or locations of origin of the conflict minerals in our supply chain for the reporting period.

After conducting due diligence on the source and chain of custody of the Conflict Minerals in our products, we found our products to be DRC conflict undeterminable, as indicated below.

Table 1: List of Logitech DRC Conflict Undeterminable Products

 

Product Category

  

Products

  

Potentially include

“Conflict
Minerals”

(Yes / No)

  

DRC Conflict

Status

PC Gaming    Gaming mice, keyboards, headsets and other controllers (e.g. steering wheel, joystick, gamepad)    Y    DRC Conflict undeterminable
  

 

Mouse pad (hard pad, cloth pad)

   N    Not Applicable
Tablet & Other Accessories   

Tablet keyboard and other accessories

 

   Y    DRC Conflict undeterminable
   Folio protective cases (without keyboard)    N    Not Applicable


Smartphone battery packs Y DRC Conflict undeterminable
Smartphone cases, tilt panel, drive mount N Not Applicable
Mobile Speakers Includes portable wireless Bluetooth speakers. Y DRC Conflict undeterminable
Pointing Devices PC related mice, trackpads, touchpads, and presenters Y DRC Conflict undeterminable
PC Keyboards & Desktops Includes PC keyboards, keyboards used in living rooms and keyboard/mice combo products. Y DRC Conflict undeterminable
Audio-PC & Wearables PC speakers, PC headsets, and in-ear headphones Y DRC Conflict undeterminable
Video Retail webcam products as well as Unified Communications webcams. Y DRC Conflict undeterminable
Remotes Harmony remote controls Y DRC Conflict undeterminable
Other (products we currently intend to transition out of or have already transitioned out) This category comprises a variety of products out of which we currently intend to transition, or have transitioned, because they are no longer strategic to our business. Products currently included in this category include TV camera, Digital Video Security (DVS), other gaming and music products, including over-ear headphones, TV and home speakers, Google TV products, and PC Keyboards & Desktops accessories. Y DRC Conflict undeterminable
Video conferencing (sold under the brand “Lifesize”) HD video communication endpoints, HD video conferencing systems with integrated monitors, video bridges and other infrastructure Y

DRC Conflict

undeterminable


Table 2: Logitech’s determination for each Conflict Mineral in 2014

 

Metal

  

Smelters and refiners verified as conflict-free or
in the audit process

  

Countries of origin status

Tantalum    39 of 48 (81%)    DRC Conflict undeterminable
Tin    51 of 153 (33%)    DRC Conflict undeterminable
Tungsten    32 of 62 (52%)    DRC Conflict undeterminable
Gold    80 of 160 (50%)    DRC Conflict undeterminable

Item 1.02 Exhibit

Notice of Conflict Mineral Report Filing

In accord with Rule 13p-1 under the Securities Exchange Act of 1934 (‘Rule 13p-1”), Logitech has filed this Specialized Disclosure Form (Form SD) and the associated Conflict Minerals Report and both reports may be accessed on the Securities and Exchange Commission’s Web site at http://www.sec.gov , as well as on Logitech’s website at http://ir.logitech.com/sec.cfm .

Section 2 – Exhibits

Item 2.01 Exhibits

Exhibit 1.01 – Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

* * * * *


SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

 

LOGITECH INTERNATIONAL S.A.

/s/ BRACKEN P. DARRELL

May 29, 2015
Bracken P. Darrell
President and Chief Executive Officer

 

* Print name and title of the registrant’s signing executive officer under his or her signature.

* * * * *



Exhibit 1.01

LOGITECH INTERNATIONAL S.A.

CONFLICT MINERALS REPORT

FOR THE REPORTING PERIOD FROM JANUARY 1 TO DECEMBER 31, 2014

SECTION ONE: INTRODUCTION

This report for the year ended December 31, 2014 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). In this Conflict Minerals Report (“CMR”), references to “Logitech”, the “Company”, “we”, “us” or “our” refer to Logitech International S.A. and its majority-owned subsidiaries and variable interest entities that are required to be consolidated.

Logitech manufactures or contracts to manufacture products that may contain gold, tantalum, tin and tungsten (“3TG”) that are necessary to the functionality or production of the products. Accordingly, the Company has undertaken the measures described in this CMR to trace the origin of these minerals and whether they may have been sourced from the Democratic Republic of Congo (“DRC”) or any of its adjoining countries (collectively, the “Covered Countries”).

1. Company Overview

Logitech International S.A., together with its consolidated subsidiaries, (“Logitech” or the “Company”) is a world leader in products that connect people to the digital experiences they care about. Spanning multiple computing, communication and entertainment platforms, we develop and market innovative hardware and software products that enable or enhance digital navigation, music and video entertainment, gaming, social networking, and audio and video communication over the Internet and home-entertainment control.

Logitech was founded in Switzerland in 1981, and Logitech International S.A. has been the parent holding company of Logitech since 1988. Logitech International S.A. is a Swiss holding company with its registered office in Apples, Switzerland, which conducts its business through subsidiaries in Americas (including North and South America), EMEA (Europe, Middle East, Africa) and Asia Pacific (including, among other countries, China, Taiwan, Japan and Australia). Shares of Logitech International S.A. are listed on both the Nasdaq Global Select Market, under the trading symbol LOGI, and the SIX Swiss Exchange, under the trading symbol LOGN.

The Company has two operating segments, peripherals and video conferencing. Logitech’s peripherals segment encompasses the design, manufacturing and marketing of peripherals for personal computers (“PCs”), tablets and other digital platforms. The Company’s video conferencing segment offers scalable high-definition (“HD”) video communications endpoints, HD video conferencing systems with integrated monitors, video bridges and other infrastructure software and hardware to support large-scale video deployments, and services to support these products.


SECTION TWO: LOGITECH PRODUCTS

The Table 1 below lists the product categories developed and marketed by Logitech for the reporting period from January 1 to December 31, 2014. These products are more fully described in our Annual Report, which can be accessed on our Web site or on the Securities and Exchange Commission’s Web site at http://www.sec.gov, and the reports we file that are published by the SIX Swiss Exchange may be accessed at: http://www.six-exchange-regulation.com/obligations/management_transactions_en.html.

The vast majority of the Logitech products are electronic devices which include electronic and electrical components and semiconductors. Because of their specific properties, the 3TG are widely used in semiconductors and in electronic components generally and, by way of consequence, in the consumer electronics industries. This is why Logitech has considered that almost all of its product categories may potentially include one or several Conflict Mineral(s). Accordingly, Logitech has included in the scope of its Conflict Minerals plan all products qualifying as electronic devices. The only product categories that have been excluded from the scope of the Conflict Minerals plan are those related to so-called “passive devices”, namely devices which do not include electronic or electric components, nor any semi-conductors, nor any other metallic component made of any of the 3TG. These excluded categories are included in Table 1, below and consist of: (i) folio protective cases for tablets; (ii) protective cases for smartphones and other non-electronic, non-electric accessories for smartphones (such as tilt panels, car mounts); (iii) mouse pads.

Table 1: List of Logitech DRC Conflict Undeterminable Products

 

Product Category

  

Products

  

Potentially include

“ConflictMinerals”

(Yes / No)

  

DRC Conflict

Status

PC Gaming    Gaming mice, keyboards, headsets and other controllers (e.g. steering wheel, joystick, gamepad)    Y    DRC Conflict undeterminable
  

 

Mouse pad (hard pad, cloth pad)

   N    Not Applicable
Tablet & Other Accessories    Tablet keyboard and other accessories    Y    DRC Conflict undeterminable


Folio protective cases (without keyboard) N Not Applicable
Smartphone battery packs Y DRC Conflict undeterminable
Smartphone cases, tilt panel, drive mount N Not Applicable
Mobile Speakers Includes portable wireless Bluetooth speakers. Y DRC Conflict undeterminable
Pointing Devices PC related mice, trackpads, touchpads, and presenters Y DRC Conflict undeterminable
PC Keyboards & Desktops Includes PC keyboards, keyboards used in living rooms and keyboard/mice combo products. Y DRC Conflict undeterminable
Audio-PC & Wearables PC speakers, PC headsets, and in-ear headphones Y DRC Conflict undeterminable
Video Retail webcam products as well as Unified Communications webcams Y DRC Conflict undeterminable
Remotes Harmony remote controls Y DRC Conflict undeterminable


Other (products we currently intend to transition out or have already transitioned out) This category comprises a variety of products out of which we currently intend to transition, or have transitioned, because they are no longer strategic to our business. Products currently included in this category include TV camera, Digital Video Security (DVS), other gaming and music products, including over-ear headphones, TV and home speakers, Google TV products, and PC Keyboards & Desktops accessories. Y DRC Conflict undeterminable

Video conferencing

(sold under the brand

“Lifesize”)

HD video communication endpoints, HD video conferencing systems with integrated monitors, video bridges and other infrastructure Y DRC Conflict undeterminable

Logitech is currently transitioning out certain products in its peripherals operating segment. These are identified in Table 1 above under “Other”. Logitech has included in the scope of its Conflict Minerals plan any product under this category that has been manufactured or marketed during the reporting period from January 1 to December 31, 2014.

Logitech may modify in the future the above categorization of its products in line with the requirement to adapt the category classification to business needs.

SECTION THREE: CONFLICT MINERALS DETERMINATION

For the reporting period from January 1 to December 31, 2014, Logitech conducted due diligence on the source and chain of custody of the conflict minerals that are necessary to the functionality or production of the products (“necessary conflict minerals”) that we manufactured or contracted to manufacture, after January 1st, 2014, for which the results of our reasonable country of origin inquiry and the diligence measures conducted on these conflict minerals were as follows:

 

    We were not able to obtain adequate information from our supply chain to be able to make any determination as to the source of these conflict minerals.

These conflict minerals we define collectively as the “CMR conflict minerals” (the “CMR Conflict Minerals”).

Therefore, these products that we manufacture that are subject to the reporting obligations of Rule 13p-1 are “DRC conflict undeterminable”, because we have been unable to determine the origin of the 3TG they contain or to determine whether they came from recycled or scrap sources; the facilities used to process them; their country of origin; or their mine or location of origin. (Please also refer to Table 1 within this report for additional details).

The Company continues to implement and pursue processes to ensure in the future that it is able to obtain the information necessary to make a determination.

SECTION FOUR: DUE DILIGENCE MEASURES

We conducted due diligence on the source and chain of custody of the conflict minerals that are necessary to the functionality or production of our products to ascertain whether these conflict minerals originated in the Covered Countries and financed or benefitted non-state armed groups in any of these countries.


Design of Our Due Diligence Measures

Our conflict minerals due diligence measures have been designed to conform with the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, Second Edition (the “OECD Guidance”), as applicable for tin, tantalum, tungsten, gold and downstream companies (as the term is defined in the OECD Guidance), in all material respects. We designed our due diligence measures to:

 

  1. establish strong Company management systems for conflict minerals supply chain due diligence;

 

  2. identify and assess conflict minerals risks in our supply chain;

 

  3. design and implement strategies to respond to conflict minerals risks identified;

 

  4. contribute to independent third-party audits of the due diligence practices of conflict minerals smelters and refiners by participating in industry organizations;

 

  5. report on our conflict minerals supply chain due diligence activities.

Due Diligence Measures Performed

Logitech’s due diligence measures were based on multi-industry initiatives with the smelters and refiners of conflict minerals who provide those conflict minerals to Logitech’s suppliers. As a purchaser, Logitech is many steps removed from the mining of the conflict minerals; Logitech does not purchase raw ore or unrefined conflict minerals, and does no purchasing in the Covered Countries. The smelters and refiners are consolidating points for raw ore and are in the best position in the total supply chain to know the origin of the ores. For downstream users like Logitech, it is not possible to determine the origin of conflict minerals without information and clarification from suppliers and smelters.

As a member in the Conflict Free Sourcing Initiative (the “CFSI”), we leveraged the due diligence conducted on smelters and refiners by the CFSI’s Conflict-Free Smelter Program (the “CFSP”). The CFSP uses independent private sector auditors to audit the source, including mines of origin, and chain of custody of the conflict minerals used by smelters and refiners that agree to participate in the CFSP. The smelters and refiners that are found to be CFSP compliant are those for which the independent auditor has verified that the smelter’s or refiner’s conflict minerals originated from conflict free mines in the Democratic Republic of the Congo or any of its adjoining countries.


Our due diligence measures included the following activities:

 

1) We utilised the already established internal team to implement Logitech’s Conflict Minerals Program again in 2014. The core team members are comprised from the following business units: Sustainability; Lifesize Compliance; Global Sourcing; Supplier Development Team; Legal; Investor Relations and Finance;

 

2) We maintained public availability of a Conflict Mineral Policy in 2014 at: http://www.logitech.com/assets/51186/logitech-policy-on-conflict-minerals-jan-2014-signed.pdf;

 

3) We established requirements and incorporated these requirements into our standard supplier contracts to define Logitech expectations of suppliers regarding sourcing of conflict minerals and reporting of information to Logitech. These requirements have been provided in our contracts as we entered into new supplier contracts or renewed existing ones. We have amended a certain number of supplier contracts that have been in place for several years. We continue to pursue flow down clauses with all impacted suppliers. In the meantime we are working with the relevant suppliers to insure they provide the 3TG sourcing information until the contracts can be amended;

 

4) We chose to engage with all our direct suppliers of materials, parts, components or products containing 3TG based on the widespread use of 3TG (“3TG Direct Suppliers”). Given our position in the supply chain, we relied heavily on our first-tier suppliers to provide information about the sources of the 3TG used in our products and to identify whether those sources may be from the DRC or an adjoining country;

 

5) We conducted a survey of our 3TG Direct Suppliers using the CFSI Conflict Minerals Reporting Template (the “Template”), which included questions about the location or mine of origin, and obligated those suppliers to make similar efforts to survey their supply chain using the Template and report the facilities and location or mine of origin for necessary conflict minerals. We elected to use this Template as it is the most commonly used tool in numerous industries, thus easing the potential confusion and burden for our suppliers;

 

6) We received responses from 95.86% of the 3TG Direct Suppliers. We reviewed the responses against the criteria designed to evaluate the adequacy of responses. These criteria include, but are not limited to, untimely or incomplete responses as well as inconsistencies within the data reported in the Template;

 

7) We compared the facilities identified by relevant 3TG Direct Suppliers via the supply chain survey against the list of facilities that have received a “conflict-free” designation for tantalum, tin, tungsten and gold, such as the Conflict-Free Smelter List (“CFS List”) published by the Conflict Free Sourcing Initiative (“CFSI”); and, where a supplier indicated that the facility was certified as Conflict-Free, we ensured that the name was listed by the CFSI;


8) Based on the data collected to-date, the main risks we have identified are related to the lack of data and the quality of the data. The vast majority of the responses received from suppliers provided data at a company level or were unable to specify the smelter or refiners used in their supply chain. We are therefore unable to determine whether any of the conflict minerals reported by the suppliers were contained in products supplied to us or to validate that any of the smelters of refiners provided by our suppliers are actually in our supply chain; and

 

9) We supported the CFSI Conflict-Free Smelter Program, and required relevant 3TG Direct Suppliers in Logitech supply chain to encourage the facilities in their supply chain to participate in the CFSI Conflict-Free Smelter Program.

SECTION FIVE: DUE DILIGENCE DETERMINATION

Survey Responses

We reviewed the responses received from our 3TG Direct Suppliers resulting from the survey carried out using the Template.

Responses included the names of 423 entities listed by our suppliers as smelters or refiners. 38.06% (161) of these entities were identified as certified Conflict-Free using the CFSI Compliant Smelter and Refiner Lists. This represents a significant progress compared to calendar year 2013 report, in which Logitech had identified 57 smelters or refiners certified as Conflict-Free, which represented 15.66% of all smelters entities listed by our suppliers.

Table 2: Logitech’s determination for each Conflict Mineral in 2014

 

Metal

  

Smelters and refiners verified as conflict-free or
in the audit process

   Countries of origin status
Tantalum    39 of 48 (81%)    DRC Conflict undeterminable
Tin    51 of 153 (33%)    DRC Conflict undeterminable
Tungsten    32 of 62 (52%)    DRC Conflict undeterminable
Gold    80 of 160 (50%)    DRC Conflict undeterminable


The remaining 262 processing facilities could not be determined to be conflict-free and so the responses could not be validated and their status is deemed unknown. At the time of reporting, 41 are in the process of certification via CFSP.

Logitech supports the refinement and expansion of the list of participating smelters through its membership in the CFSI program.

A small minority of suppliers provided information at a product level or product category level. However all of these suppliers were unable to identify specifically the smelters whose 3TG went into parts supplied to Logitech.

The large majority of the responses received provided data at a company or divisional level or, as described above, were unable to specify the smelters or refiners used for components supplied to Logitech. Thus, our suppliers were unable to represent to us that 3TG from the entities they listed had actually been included in components they supplied to Logitech. In addition, 262 processing facilities were not validated as in fact being smelters or refiners.

We have therefore elected not to present the smelter and refiner names in this report, with the exception of the conflict-free smelters sourcing from Covered Countries. Please see table 3 below for further information on these facilities and their country of origin

Table 3: List of Conflict Free Smelters Determination for Logitech Products

 

Metal

  

Smelter Name

   Smelter ID   

Smelter country

  

Conflict Mineral

Free (CMF) Status

Gold    Aida Chemical Industries Co. Ltd.    CID000019    JAPAN    CMF
Gold    Allgemeine Gold-und Silberscheideanstalt A.G.    CID000035    GERMANY    CMF
Gold    Almalyk Mining and Metallurgical Complex (AMMC)    CID000041    UZBEKISTAN    CMF
Gold    AngloGold Ashanti Córrego do Sítio Minerção    CID000058    BRAZIL    CMF
Gold    Argor-Heraeus SA    CID000077    SWITZERLAND    CMF
Gold    Asahi Pretec Corporation    CID000082    JAPAN    CMF
Gold    Atasay Kuyumculuk Sanayi Ve Ticaret A.S.    CID000103    TURKEY    CMF
Gold    Aurubis AG    CID000113    GERMANY    CMF


Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines) CID000128 PHILIPPINES CMF
Gold Boliden AB CID000157 SWEDEN CMF
Gold C. Hafner GmbH + Co. KG CID000176 GERMANY CMF
Gold CCR Refinery – Glencore Canada Corporation CID000185 CANADA CMF
Gold Cendres + Métaux SA CID000189 SWITZERLAND CMF
Gold Chimet S.p.A. CID000233 ITALY CMF
Gold Dowa CID000401 JAPAN CMF
Gold Eco-System Recycling Co., Ltd. CID000425 JAPAN CMF
Gold Heimerle + Meule GmbH CID000694 GERMANY CMF
Gold Heraeus Ltd. Hong Kong CID000707 HONG KONG CMF
Gold Heraeus Precious Metals GmbH & Co. KG CID000711 GERMANY CMF
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited CID000801 CHINA CMF
Gold Ishifuku Metal Industry Co., Ltd. CID000807 JAPAN CMF
Gold Istanbul Gold Refinery CID000814 TURKEY CMF
Gold Japan Mint CID000823 JAPAN CMF
Gold Jiangxi Copper Company Limited CID000855 CHINA CMF
Gold Johnson Matthey Inc CID000920 UNITED STATES CMF
Gold Johnson Matthey Ltd CID000924 CANADA CMF
Gold JSC Ekaterinburg Non-Ferrous Metal Processing Plant CID000927 RUSSIAN FEDERATION CMF
Gold JSC Uralelectromed CID000929 RUSSIAN FEDERATION CMF


Gold JX Nippon Mining & Metals Co., Ltd. CID000937 JAPAN CMF
Gold Kazzinc Ltd CID000957 KAZAKHSTAN CMF
Gold Kennecott Utah Copper LLC CID000969 UNITED STATES CMF
Gold Kojima Chemicals Co., Ltd CID000981 JAPAN CMF
Gold Kyrgyzaltyn JSC CID001029 KYRGYZSTAN CMF
Gold L’ azurde Company For Jewelry CID001032 SAUDI ARABIA CMF
Gold LS-NIKKO Copper Inc. CID001078 KOREA, REPUBLIC OF CMF
Gold Materion CID001113 UNITED STATES CMF
Gold Matsuda Sangyo Co., Ltd. CID001119 JAPAN CMF
Gold Metalor Technologies (Hong Kong) Ltd CID001149 HONG KONG CMF
Gold Metalor Technologies (Singapore) Pte. Ltd. CID001152 SINGAPORE CMF
Gold Metalor Technologies SA CID001153 SWITZERLAND CMF
Gold Metalor USA Refining Corporation CID001157 UNITED STATES CMF
Gold Met-Mex Peñoles, S.A. CID001161 MEXICO CMF
Gold Mitsubishi Materials Corporation CID001188 JAPAN CMF
Gold Mitsui Mining and Smelting Co., Ltd. CID001193 JAPAN CMF
Gold Moscow Special Alloys Processing Plant CID001204 RUSSIAN FEDERATION CMF
Gold Nadir Metal Rafineri San. Ve Tic. A.Ş. CID001220 TURKEY CMF
Gold Navoi Mining and Metallurgical Combinat CID001236 UZBEKISTAN CMF


Gold Nihon Material Co. LTD CID001259 JAPAN CMF
Gold Ohio Precious Metals, LLC CID001322 UNITED STATES CMF
Gold Ohura Precious Metal Industry Co., Ltd CID001325 JAPAN CMF
Gold OJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastvetmet) CID001326 RUSSIAN FEDERATION CMF
Gold OJSC Kolyma Refinery CID001328 RUSSIAN FEDERATION CMF
Gold PAMP SA CID001352 SWITZERLAND CMF
Gold Prioksky Plant of Non-Ferrous Metals CID001386 RUSSIAN FEDERATION CMF
Gold PT Aneka Tambang (Persero) Tbk CID001397 INDONESIA CMF
Gold PX Précinox SA CID001498 SWITZERLAND CMF
Gold Rand Refinery (Pty) Ltd CID001512 SOUTH AFRICA CMF
Gold Royal Canadian Mint CID001534 CANADA CMF
Gold Schone Edelmetaal CID001573 NETHERLANDS CMF
Gold SEMPSA Joyería Platería SA CID001585 SPAIN CMF
Gold Shandong Zhaojin Gold & Silver Refinery Co. Ltd CID001622 CHINA CMF
Gold SOE Shyolkovsky Factory of Secondary Precious Metals CID001756 RUSSIAN FEDERATION CMF
Gold Solar Applied Materials Technology Corp. CID001761 TAIWAN CMF
Gold Sumitomo Metal Mining Co., Ltd. CID001798 JAPAN CMF
Gold Tanaka Kikinzoku Kogyo K.K. CID001875 JAPAN CMF


Gold The Refinery of Shandong Gold Mining Co. Ltd CID001916 CHINA CMF
Gold Tokuriki Honten Co., Ltd CID001938 JAPAN CMF
Gold Umicore Brasil Ltda CID001977 BRAZIL CMF
Gold Umicore Precious Metals Thailand CID002314 THAILAND CMF
Gold Umicore SA Business Unit Precious Metals Refining CID001980 BELGIUM CMF
Gold United Precious Metal Refining, Inc. CID001993 UNITED STATES CMF
Gold Valcambi SA CID002003 SWITZERLAND CMF
Gold Western Australian Mint trading as The Perth Mint CID002030 AUSTRALIA CMF
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation CID002224 CHINA CMF
Gold Zijin Mining Group Co. Ltd CID002243 CHINA CMF
Tantalum Changsha South Tantalum Niobium Co., Ltd. CID000211 CHINA CMF
Tantalum Conghua Tantalum and Niobium Smeltry CID000291 CHINA CMF
Tantalum Duoluoshan CID000410 CHINA CMF
Tantalum Exotech Inc. CID000456 UNITED STATES CMF
Tantalum F&X Electro-Materials Ltd. CID000460 CHINA CMF
Tantalum Global Advanced Metals Aizu CID002558 JAPAN CMF
Tantalum Global Advanced Metals Boyertown CID002557 UNITED STATES CMF
Tantalum Guangdong Zhiyuan New Material Co., Ltd. CID000616 CHINA CMF
Tantalum Guizhou Zhenhua Xinyun Technology Ltd., Kaili branch CID002501 CHINA CMF


Tantalum H.C. Starck Co., Ltd. CID002544 THAILAND CMF
Tantalum H.C. Starck GmbH Goslar CID002545 GERMANY CMF
Tantalum H.C. Starck GmbH Laufenburg CID002546 GERMANY CMF
Tantalum H.C. Starck Hermsdorf GmbH CID002547 GERMANY CMF
Tantalum H.C. Starck Inc. CID002548 UNITED STATES CMF
Tantalum H.C. Starck Ltd. CID002549 JAPAN CMF
Tantalum H.C. Starck Smelting GmbH & Co.KG CID002550 GERMANY CMF
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd. CID002492 CHINA CMF
Tantalum Hi-Temp CID000731 UNITED STATES CMF
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd. CID000914 CHINA CMF
Tantalum Jiujiang Tanbre Co., Ltd. CID000917 CHINA CMF
Tantalum KEMET Blue Metals CID002539 MEXICO CMF
Tantalum KEMET Blue Powder CID002568 UNITED STATES CMF
Tantalum King-Tan Tantalum Industry Ltd CID000973 CHINA CMF
Tantalum LSM Brasil S.A. CID001076 BRAZIL CMF
Tantalum Metallurgical Products India (Pvt.) Ltd. CID001163 INDIA CMF
Tantalum Mineração Taboca S.A. CID001175 BRAZIL CMF
Tantalum Mitsui Mining & Smelting CID001192 JAPAN CMF
Tantalum Molycorp Silmet A.S. CID001200 ESTONIA CMF
Tantalum Ningxia Orient Tantalum Industry Co., Ltd. CID001277 CHINA CMF


Tantalum Plansee SE Liezen CID002540 AUSTRIA CMF
Tantalum Plansee SE Reutte CID002556 AUSTRIA CMF
Tantalum QuantumClean CID001508 UNITED STATES CMF
Tantalum RFH Tantalum Smeltry Co., Ltd CID001522 CHINA CMF
Tantalum Solikamsk Magnesium Works OAO CID001769 RUSSIAN FEDERATION CMF
Tantalum Taki Chemicals CID001869 JAPAN CMF
Tantalum Telex CID001891 UNITED STATES CMF
Tantalum Ulba CID001969 KAZAKHSTAN CMF
Tantalum Yichun Jin Yang Rare Metal Co., Ltd CID002307 CHINA CMF
Tantalum Zhuzhou Cement Carbide CID002232 CHINA CMF
Tin Alpha CID000292 UNITED STATES CMF
Tin China Rare Metal Materials Company CID000244 CHINA CMF
Tin Cooper Santa CID000295 BRAZIL CMF
Tin CV United Smelting CID000315 INDONESIA CMF
Tin Dowa CID000402 JAPAN CMF
Tin EM Vinto CID000438 BOLIVIA CMF
Tin Gejiu Non-Ferrous Metal Processing Co. Ltd. CID000538 CHINA CMF
Tin Magnu’s Minerais Metais e Ligas LTDA CID002468 BRAZIL CMF
Tin Malaysia Smelting Corporation (MSC) CID001105 MALAYSIA CMF
Tin Melt Metais e Ligas S/A CID002500 BRAZIL CMF


Tin Metallo Chimique CID001143 BELGIUM CMF
Tin Mineração Taboca S.A. CID001173 BRAZIL CMF
Tin Minsur CID001182 PERU CMF
Tin Mitsubishi Materials Corporation CID001191 JAPAN CMF
Tin OMSA CID001337 BOLIVIA CMF
Tin PT ATD Makmur Mandiri Jaya CID002503 INDONESIA CMF
Tin PT Babel Inti Perkasa CID001402 INDONESIA CMF
Tin PT Bangka Putra Karya CID001412 INDONESIA CMF
Tin PT Bangka Tin Industry CID001419 INDONESIA CMF
Tin PT Belitung Industri Sejahtera CID001421 INDONESIA CMF
Tin PT Bukit Timah CID001428 INDONESIA CMF
Tin PT DS Jaya Abadi CID001434 INDONESIA CMF
Tin PT Eunindo Usaha Mandiri CID001438 INDONESIA CMF
Tin PT Mitra Stania Prima CID001453 INDONESIA CMF
Tin PT Panca Mega Persada CID001457 INDONESIA CMF
Tin PT Prima Timah Utama CID001458 INDONESIA CMF
Tin PT REFINED BANGKA TIN CID001460 INDONESIA CMF
Tin PT Sariwiguna Binasentosa CID001463 INDONESIA CMF
Tin PT Stanindo Inti Perkasa CID001468 INDONESIA CMF
Tin PT Tambang Timah CID001477 INDONESIA CMF
Tin PT Timah (Persero), Tbk CID001482 INDONESIA CMF
Tin PT Tinindo Inter Nusa CID001490 INDONESIA CMF


Tin Thaisarco CID001898 THAILAND CMF
Tin White Solder Metalurgia e Mineração Ltda. CID002036 BRAZIL CMF
Tin Yunnan Tin Company, Ltd. CID002180 CHINA CMF
Tungsten Ganzhou Huaxing Tungsten Products Co., Ltd. CID000875 CHINA CMF
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd. CID002315 CHINA CMF
Tungsten Ganzhou Seadragon W & Mo Co., Ltd. CID002494 CHINA CMF
Tungsten Global Tungsten & Powders Corp. CID000568 UNITED STATES CMF
Tungsten Hunan Chunchang Nonferrous Metals Co., Ltd. CID000769 CHINA CMF
Tungsten Japan New Metals Co., Ltd. CID000825 JAPAN CMF
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd. CID002321 CHINA CMF
Tungsten Malipo Haiyu Tungsten Co., Ltd. CID002319 CHINA CMF
Tungsten Vietnam Youngsun Tungsten Industry Co., Ltd CID002011 VIETNAM CMF
Tungsten Wolfram Bergbau und Hütten AG CID002044 AUSTRIA CMF
Tungsten Xiamen Tungsten (H.C.) Co., Ltd. CID002320 CHINA CMF
Tungsten Xiamen Tungsten Co., Ltd. CID002082 CHINA CMF

Efforts to Determine the Conflict Minerals’ Mine or Location of Origin –

Through our participation in CFSI, the OECD implementation programs, and requesting our suppliers to complete The Template, we have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the mines or locations of origin of the 3TG in our supply chain, as outlined in Section Four “Due Diligence Measures” above.


SECTION SIX: NEXT STEPS

Logitech will undertake the following steps, during the next compliance period, with the intention of further mitigating the risk that its supply chain sourcing, utilizing necessary conflict minerals may benefit armed groups, including:

 

    Attempting to increase the response rate of suppliers and improve the content of the responses by contracting a third party specialist to engage with these suppliers on an individual basis to understand their challenges in compliance and support their transition.

 

    Requesting relevant suppliers to request smelters to participate in obtaining a conflict free designation from an industry program such as the EICC/GeSI Conflict Free Smelter program.

 

    Attempting to validate supplier responses using information collected via independent conflict free smelter validation programs such as the Electronic Industry Citizenship Coalition Global e-Sustainability Initiative (EICC/GeSI) Conflict Free Smelter program to which we provide financial support.

 

    Increasing the number of relevant supplier contracts that include our requirements or obtaining industry standards demonstration of implementation of our standards, by utilising the Conflict Minerals Report template.

 

    Future Non-Conformance: Discontinue doing business with any Logitech Suppliers whom are unable to meet our Conflict Minerals Policy.
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